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and commercial bank. In 2006, he was recognized as the Capital Markets CIO of the Year by Bankers Magazine. From 1992-2001, Mr. Torgovnik was with JP Morgan in a variety of technology roles within their Fixed Income Derivatives business, including Global Head of Fixed Income Derivatives Technology and F
s Commission, The Center, 99 Queens Road Central, Central Hong Kong, Tel. +852 3965 3222. • Millennium Capital Management (Singapore) Pte. Ltd. ("MCM Singapore"), a wholly-owned subsidiary of Millennium International Management, which is licensed by the Monetary Authority of Singapore, 80 Raffles Place, UO
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
be) are not obtained from such operation; or d. a designated person22. The Master Partnership, Millennium Management, the Investment Manager and MCM Singapore reserve the right to request such information as any of the Master Partnership, Millennium Management, the Investment Manager and MCM Singapore (as
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
of making a personal profit (or incurring a personal loss). The ownership structure of MCP UK may change from time to time without notice. Each of MCM Singapore, MCM FIK, and MCM Asia's Tokyo Branch (collectively, the "Asia Entities") is owned by Millennium International Management. The capital to establish
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
be) are not obtained from such operation; or d. a designated person22. The Master Partnership, Millennium Management, the Investment Manager and MCM Singapore reserve the right to request such information as any of the Master Partnership, Millennium Management, the Investment Manager and MCM Singapore (as
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
of making a personal profit (or incurring a personal loss). The ownership structure of MCP UK may change from time to time without notice. Each of MCM Singapore, MCM FIK, and MCM Asia's Tokyo Branch (collectively, the "Asia Entities") is owned by Millennium International Management. The capital to establish
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
Entities connected to both JPMorgan Chase and Cayman Islands Tax Matters

Ghislaine Maxwell
PERSON
the Internal Revenue Service
ORGANIZATION
Marc Rich
PERSONthe State of New York
LOCATION
George W. Bush
PERSON
Federal Reserve
ORGANIZATION
United States
LOCATION
Samantha Power
PERSON
Greenwich
LOCATION
New York
LOCATION
United Kingdom
LOCATIONthe Securities and Exchange Commission
ORGANIZATION
Department of Justice
ORGANIZATION
Wilbur Ross
PERSON
U.S. Treasury
ORGANIZATION
New York State
LOCATION
Malaysia
LOCATION
UBS AG
ORGANIZATIONCayman
LOCATION
Dallas
LOCATION