3
Shared Docs
3
Same-Page
4 / 3
Mentions
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
n Investor other than its investment in the AlphaKeys Fund may affect the tax consequences to such Investor of an investment in the AlphaKeys Fund. Treatment as Partnership. It is intended that the AlphaKeys Fund will be treated as a partnership for U.S. federal income tax purposes and not as an association or "publicly
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
nvestor other than its investment in the Alpha Keys Fund may affect the tax consequences to such Investor of an investment in the Alpha Keys Fund. Treatment as Partnership. It is intended that the Alpha Keys Fund will be treated as a partnership for U.S. federal income tax purposes and not as an association or "public
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
nvestor other than its investment in the Alpha Keys Fund may affect the tax consequences to such Investor of an investment in the Alpha Keys Fund. Treatment as Partnership. It is intended that the Alpha Keys Fund will be treated as a partnership for U.S. federal income tax purposes and not as an association or "public
Entities connected to both U.S. Treasury and Treatment as Partnership

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
Paul Volcker
PERSON
FDIC
ORGANIZATIONthe Federal Reserve System
ORGANIZATIONErnst & Young LLP
ORGANIZATIONthe New York Stock Exchange
ORGANIZATIONthe U.S. Department of Labor
ORGANIZATION
Cayman Islands
LOCATIONSchulte Roth & Zabel LLP
ORGANIZATION
Millennium
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION