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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
ption of Additional Classes PART Two: INFORMATION RELATING TO MILLENNIUM PARTNERS, L.P. Sununary of Part Two of the Confidential Memorandum II-1 The Fund's Investment Program and Strategy II-8 The Master Partnership's Organization 11-9 Certain Risk Factors Relating to an Investment in the Fund II-11
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
ent Public Accountants 1-80 PART Two: INFORMATION RELATING TO MILLENNIUM PARTNERS, L.P. Summary of Part Two of the Confidential Memorandum II-1 The Fund's Investment Program and Strategy 11-8 The Master Partnership's Organization II-9 Certain Risk Factors Relating to an Investment in the Fund II-11
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
ndent Public Accountants 1-80 PART Two: INFORMATION RELATING TO MILLENNIUM PARTNERS, M. Summary of Part Two of the Confidential Memorandum II-1 The Fund's Investment Program and Strategy 11-8 The Master Partnership's Organization II-9 Certain Risk Factors Relating to an Investment in the Fund II-11
Entities connected to both U.S. Treasury and The Fund's

United States
LOCATION
Ghislaine Maxwell
PERSON
New York
LOCATION
UBS AG
ORGANIZATION
Philadelphia
LOCATIONCayman
LOCATION
the Internal Revenue Service
ORGANIZATION
Federal Reserve
ORGANIZATIONthe District of Columbia
LOCATIONKeogh
ORGANIZATION
FDIC
ORGANIZATION
Paul Volcker
PERSONthe Federal Reserve System
ORGANIZATIONErnst & Young LLP
ORGANIZATIONthe U.S. Department of Labor
ORGANIZATIONthe New York Stock Exchange
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
the Cayman Islands
LOCATION
Cayman Islands
LOCATION
Millennium
ORGANIZATION