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nsult with their tax advisors to fully understand the tax consequences of an investment in the AlphaKeys Fund. This summary is based upon the Code, the U.S. Treasury regulations ("Treasury Regulations") promulgated thereunder, published rulings, court decisions and other applicable authorities, all as in effect
result in a greater economic cost for a particular Investors. The partnership audit rules will also apply to an audit of the Underlying Fund. While the Treasury Department has issued proposed and temporary final Treasury Regulations implementing these rules, there continues to be substantial uncertainty regarding cert
is urged to consult with its own tax advisor regarding the U.S. and non-U.S. tax treatment of an investment in the AlphaKeys Fund. Implications of Non-U.S. Investments Certain non-U.S. investments of the Underlying Fund and the Underlying Master Fund, including investments in "controlled foreign corporations" and
2 mentions1 same-page
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nsult with their tax advisors to fully understand the tax consequences of an investment in the AlphaKeys Fund. This summary is based upon the Code, the U.S. Treasury regulations ("Treasury Regulations") promulgated thereunder, published rulings, court decisions and other applicable authorities, all as in effect
is urged to consult with its own tax advisor regarding the U.S. and non-U.S. tax treatment of an investment in the AlphaKeys Fund. Implications of Non-U.S. Investments Certain non-U.S. investments of the Underlying Fund and the Underlying Master Fund, including investments in "controlled foreign corporations" and
2 mentions1 same-page
Page ?Same page
nsult with their tax advisors to fully understand the tax consequences of an investment in the AlphaKeys Fund. This summary is based upon the Code, the U.S. Treasury regulations ("Treasury Regulations") promulgated thereunder, published rulings, court decisions and other applicable authorities, all as in effect
is urged to consult with its own tax advisor regarding the U.S. and non-U.S. tax treatment of an investment in the AlphaKeys Fund. Implications of Non-U.S. Investments Certain non-U.S. investments of the Underlying Fund and the Underlying Master Fund, including investments in "controlled foreign corporations" and
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Mutual Connections (119)
Entities connected to both U.S. Treasury and Non-U.S. Investments
United States
LOCATION197 w/ U.S.·5 w/ Non-U.S.
Ghislaine Maxwell
PERSON135 w/ U.S.·2 w/ Non-U.S.
New York
LOCATION79 w/ U.S.·3 w/ Non-U.S.
UBS AG
ORGANIZATION67 w/ U.S.·3 w/ Non-U.S.
Philadelphia
LOCATION56 w/ U.S.·2 w/ Non-U.S.
Cayman
LOCATION45 w/ U.S.·4 w/ Non-U.S.
the Internal Revenue Service
ORGANIZATION38 w/ U.S.·4 w/ Non-U.S.
Federal Reserve
ORGANIZATION33 w/ U.S.·2 w/ Non-U.S.
the District of Columbia
LOCATION29 w/ U.S.·4 w/ Non-U.S.
Keogh
ORGANIZATION18 w/ U.S.·2 w/ Non-U.S.
FDIC
ORGANIZATION16 w/ U.S.·2 w/ Non-U.S.
Paul Volcker
PERSON15 w/ U.S.·3 w/ Non-U.S.
the Federal Reserve System
ORGANIZATION9 w/ U.S.·3 w/ Non-U.S.
Ernst & Young LLP
ORGANIZATION9 w/ U.S.·3 w/ Non-U.S.
the U.S. Department of Labor
ORGANIZATION8 w/ U.S.·2 w/ Non-U.S.
the Cayman Islands
LOCATION8 w/ U.S.·2 w/ Non-U.S.
the New York Stock Exchange
ORGANIZATION8 w/ U.S.·2 w/ Non-U.S.
Cayman Islands
LOCATION8 w/ U.S.·2 w/ Non-U.S.
Millennium
ORGANIZATION6 w/ U.S.·3 w/ Non-U.S.
the U.S. Investment Company Act
ORGANIZATION6 w/ U.S.·3 w/ Non-U.S.