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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
f this Agreement, the transferee shall succeed to the Capital Account of the transferor to the extent it relates to the transferred Interest. 5.4 Allocation of Net Profit and Net Loss. As of the last day of each Fiscal Period, any Net Profit or Net Loss for the Fiscal Period shall be allocated among and credited to or debited agai
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
f this Agreement, the transferee shall succeed to the Capital Account of the transferor to the extent it relates to the transferred Interest. 5.4 Allocation of Net Profit and Net Loss. As of the last day of each Fiscal Period, any Net Profit or Net Loss for the Fiscal Period shall be allocated among and credited to or debited agai
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
f this Agreement, the transferee shall succeed to the Capital Account of the transferor to the extent it relates to the transferred Interest. 5.4 Allocation of Net Profit and Net Loss. As of the last day of each Fiscal Period, any Net Profit or Net Loss for the Fiscal Period shall be allocated among and credited to or debited agai
Entities connected to both Cayman Islands Tax Matters and Allocation of Net Profit and Net Loss
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