3
Shared Docs
3
Same-Page
3 / 3
Mentions
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
a, Minato-ku, Tokyo 107-6243, Tel. + 03 6757 5800. • Millennium Capital Partners LLP ("MCP UK," and together with MCP Switzerland, MCM Australia, MCM Asia, MCM HK and MCM Singapore, the "Foreign Advisers"), which is registered with the United Kingdom Financial Conduct Authority ("FCA") as an investmen
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
0; • Millennium Capital Management (Asia) Limited, a wholly-owned subsidiary of Millennium International Management, including its Tokyo branch ("MCM Asia"), which Tokyo branch is licensed by the Japanese Financial Services Authority, Tokyo Midtown Tower, 43nd Floor, 9-7-I Akasaka, Minato-ku, Tokyo 10
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
. I • Millennium Capital Management (Asia) Limited, a wholly-owned subsidiary of Millennium International Management, including its Tokyo branch ("MCM Asia"), which Tokyo branch is licensed by the Japanese Financial Services Authority, Tokyo Midtown Tower, 43n1 Floor, 9-7-I Akasaka, Minato-ku, Tokyo 10
Entities connected to both Cayman Islands Tax Matters and MCM Asia
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