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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
forth in the Recitals. Series shall have the meaning set forth in Section 2.8 hereof. Soliciting Members means Members representing at least 20% in Interest of the Fund who are requesting a meeting of the Members. Sub-Class shall have the meaning set forth in Section 2.8 hereof. Temporary Investments means money m
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
o Section 5.7 hereof). Series shall have the meaning set forth in Section 2.8 hereof. Soliciting Members means Members representing at least 20% in Interest of the Fund who are requesting a meeting of the Members. Tax Matters Partner means the Member designated as "tax matters partner" of the Fund pursuant to Sect
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
o Section 5.7 hereof). Series shall have the meaning set forth in Section 2.8 hereof. Soliciting Members means Members representing at least 20% in Interest of the Fund who are requesting a meeting of the Members. Tax Matters Partner means the Member designated as "tax matters partner" of the Fund pursuant to Sect
Entities connected to both Cayman Islands Tax Matters and Interest of the Fund
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