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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
iary of Millennium International Management. • Cannon Asset Management LLC, a wholly-owned subsidiary of Millennium International Management. • Catapult Capital Management LLC, a wholly-owned subsidiary of Millennium International Management. • Decade Capital Management LLC, a wholly-owned subsidiary of Millennium Inter
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
gement"); • Millennium Global Estate GP LLC ("Millennium Global Estate GP"), a wholly-owned subsidiary of Millennium International Management; • Catapult Capital Management LLC, a wholly-owned subsidiary of Millennium International Management; ML281817-MAXWELL 11-37 CONFIDENTIAL UBSTERRAMAR00002453 EFTA00238009 • De
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
gement"); • Millennium Global Estate GP LLC ("Millennium Global Estate GP"), a wholly-owned subsidiary of Millennium International Management; • Catapult Capital Management LLC, a wholly-owned subsidiary of Millennium International Management; MAXWELL 11-37 CONFIDENTIAL UBSTERRAMAR00001400 EFTA00237046 • Decade Capi
Entities connected to both Cayman Islands Tax Matters and Catapult Capital Management LLC
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