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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
income tax purposes, in his, her or its Interest in the Fund as of such time (determined without regard to such Member's share of the liabilities of the Fund under Section 752 of the Code, if any). Positive Basis Member means any Member who withdraws from the Fund and who has Positive Basis as of the effective date of th
itted by any of Millennium's employees or agents or persons acting on their behalf. 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
income tax purposes, in his, her or its Interest in the Fund as of such time (determined without regard to such Member's share of the liabilities of the Fund under Section 752 of the Code, if any). ML281817-MAXWELL B-S CONFIDENTIAL UBSTERRAMAR00002486 EFTA00238042 Positive Basis Member means any Member who withdraws
itted by any of Millennium's employees or agents or persons acting on their behalf. 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
income tax purposes, in his, her or its Interest in the Fund as of such time (determined without regard to such Member's share of the liabilities of the Fund under Section 752 of the Code, if any). NMI MAXWELL B-S CONFIDENTIAL UBSTERRAMAR00001433 EFTA00237079 Positive Basis Member means any Member who withdraws fro
Entities connected to both Cayman Islands Tax Matters and the Fund under Section 752
the Cayman Islands Monetary Authority
ORGANIZATION
New York State
LOCATIONthe Non-USD Shares
ORGANIZATION
Millennium
ORGANIZATIONErnst & Young LLP
ORGANIZATIONMillennium USA LP
ORGANIZATION
Mohammed bin Salman
PERSONCayman
LOCATION
England
LOCATION
New York
LOCATIONthe Mutual Funds Law
ORGANIZATION
United States
LOCATION
Tokyo
LOCATIONLehman
ORGANIZATION
JPMorgan Chase
ORGANIZATIONMillennium Management LLC
ORGANIZATIONthe Exempted Limited Partnership Law
ORGANIZATIONLegal and Regulatory Matters Relating
ORGANIZATIONCayman Islands Mutual Funds Law
ORGANIZATIONThe Fund's Risk Management Program
ORGANIZATION