e US IGA and the UK IGA, and on 16 October 2015 to give effect to the CRS (collectively. the "AEOI Regulations"). Pursuant to the AEOI Regulations, the Cayman Islands Tax Information Authority (the "TIA") has published guidance notes on the application of the US and UK IGAs and has the power to issue guidance in relation to the CRS. Gene

ded to the Master Partnership and certain financial information related to such investor's investment in the Master Partnership will be shared with the Cayman Islands Tax Information Authority or its delegate (the "Cayman TIA"). The Cayman TIA will exchange the information reported to it with the Service annually on an automatic basis. A