Epstein Secrets

Act, 50 U.S.C. § 1701 et seq., (iv) the Trading with the Enemy Act, 50 U.S.C. App. 1 et seq. and (v) any related rules and regulations of the U.S. Treasury Department's Office of Foreign Assets Control or any other governmental authority, in each case as the same may be amended, supplemented, modified, replaced or o

ns provided for in this Agreement do not comply with the substantial economic effect and capital account rules set forth under Code Section 704 and the Treasury Regulations thereunder or otherwise properly reflect the economic interests of the Members, the Managing Member shall make such modifications to the allocation

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

ry income. Furthermore, a 3.8% Medicare contribution tax will be imposed on the "net investment income" (as defined in Section 1411 of the Code and the Treasury Regulations thereunder) of individuals whose income exceeds certain threshold amounts and of certain trusts and estates under similar rules. Investors are advis

rth in Section 10.1(b)(i). "Transferor" shall have the meaning set forth in Section 10.1(bXi). "Treasury Regulations" shall mean the regulations of the Treasury Department issued pursuant to the Code, as amended from time to time. "UBS" shall mean UBS AG and any of its affiliates. "UBSFA" shall mean UBS Fund Advisor,

respect to each Member as provided in Section 1.10. (c) The provisions of this Agreement are intended to comply with Section 7O4(b) of the Code and the Treasury Regulations promulgated thereunder and shall be interpreted and applied in a manner consistent with such Section and such Treasury Regulations. ER305378-MAXWEL