Epstein Secrets

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

out herein concerning the AlphaKeys Fund or the Administrator, other service providers and their affiliates and personnel. Custodian/Escrow Agent The Bank of New York Mellon (the "Custodian") serves as the primary custodian of the assets of the AlphaKeys Fund, and may maintain custody of such assets with domestic and non

a foreign financial institution and is subject to the diligence and reporting requirements in clause (1) above, it must enter into an agreement with the U.S. Treasury requiring, among other things, that it undertake to identify accounts held by certain U.S. persons or U.S.-owned foreign entities, annually report

nflicting interest relating to any of its duties with respect to the debt securities, however, it must eliminate the conflict or resign as Trustee. The Bank of New York Mellon is the Trustee under the Indenture. Governing Law The Indenture and the debt securities will be governed by, and construed in accordance with, the

t with their own 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

AlphaKeys Fund to limit the transferability of Interests to Benefit Plan Investors or to Disregarded Parties. Ropes & Gray LLP Ernst & Young LLP The Bank of New York Mellon ER305378-MAXWELL -21- CONFIDENTIAL UBSTERFtAMAR00001802 EFTA00237433 ER305378-MAXWELL -22- CONFIDENTIAL UBSTERFtAMAR00001803 EFTA00237434