Cayman Islands Tax Matters
ORGANIZATIONMillennium Capital Management (Singapore) Pte. Ltd.
ORGANIZATION3
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76 CONFIDENTIAL UBSTERRAMAR00004079 EFTA00239411 FOR EXISTING INVESTOR USE ONLY Certain Tax Matters Relating to the Master Partnership Certain Cayman Islands Tax Matters THE FOLLOWING IS A SUMMARY OF CERTAIN CAYMAN ISLANDS TAX CONSEQUENCES TO PERSONS WHO PURCHASE INTERESTS IN THE OFFERING. THE DISCUSSION IS BASED U
ch is licensed by the Hong Kong Securities and Futures Commission, The Center, 99 Queens Road Central, Central Hong Kong, Tel. +852 3965 3222. • Millennium Capital Management (Singapore) Pte. Ltd. ("MCM Singapore"), a wholly-owned subsidiary of Millennium International Management, which is licensed by the Monetary Authority of Singapore, 80
limited partnership in the Cayman Islands and therefore, as described below under "Certain Tax Matters Relating to the Master Partnership — Certain Cayman Islands Tax Matters," general and limited partners in the Master Partnership are not currently subject to income, corporation, capital gains or other taxes in the Cayma
Millennium International Management; • Green Arrow Capital Management LLC, a wholly-owned subsidiary of Millennium International Management; • Millennium Capital Management (Singapore) Pte. Ltd. ("MCM Singapore"), a wholly-owned subsidiary of Millennium International Management, which is licensed by the Monetary Authority of Singapore, 80
limited partnership in the Cayman Islands and therefore, as described below under "Certain Tax Matters Relating to the Master Partnership — Certain Cayman Islands Tax Matters," general and limited partners in the Master Partnership are not currently subject to income, corporation, capital gains or other taxes in the Cayma
Millennium International Management; • Green Arrow Capital Management LLC, a wholly-owned subsidiary of Millennium International Management; • Millennium Capital Management (Singapore) Pte. Ltd. ("MCM Singapore"), a wholly-owned subsidiary of Millennium International Management, which is licensed by the Monetary Authority of Singapore, 80
Entities connected to both Cayman Islands Tax Matters and Millennium Capital Management (Singapore) Pte. Ltd.
the Cayman Islands Monetary Authority
ORGANIZATIONCayman
LOCATION
Millennium
ORGANIZATIONMillennium USA LP
ORGANIZATION
Mohammed bin Salman
PERSON
England
LOCATION
New York
LOCATION
New York State
LOCATIONthe Non-USD Shares
ORGANIZATIONthe Mutual Funds Law
ORGANIZATIONErnst & Young LLP
ORGANIZATION
Tokyo
LOCATION
JPMorgan Chase
ORGANIZATION
United States
LOCATIONLehman
ORGANIZATIONthe "Service
ORGANIZATIONthe Commodity Futures Trading Commission
ORGANIZATIONCapital Formation International
ORGANIZATIONNovogratz
PERSON
Greenwich
LOCATION