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

ts investments from outside investors and primarily invests its capital in the Master Partnership (or its underlying strategies) indirectly through Millennium Offshore Intermediate, L.P., a Cayman Islands exempted limited partnership (the "Intermediate Partnership"), which, in turn, invests all or substantially all of its capi

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

hip"). Millennium International, Ltd. ("Millennium International"), accepts investments from outside investors and primarily invests its capital in Millennium Offshore Intermediate, L.P., a Cayman Islands exempted limited partnership (the "Intermediate Partnership"), which, in turn, invests all or substantially all of its capi

ich are not deductible by a noncorporate taxpayer in calculating its alternative minimum tax liability. Pursuant to Temporary Regulations issued by the Treasury Department, these limitations on deductibility should not apply to a noncorporate Limited Partner's share of the expenses of the Master Partnership to the ext

ty company that was formed in 1994. The General Partner also serves as the sole general partner of Millennium USA, Millennium Strategic Capital and Millennium Offshore Intermediate. The General Partner is considered to be under the ultimate control of Israel Englander. The business address and telephone number of the General

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

hip"). Millennium International, Ltd. ("Millennium International"), accepts investments from outside investors and primarily invests its capital in Millennium Offshore Intermediate, •., a Cayman Islands exempted limited partnership (the "Intermediate Partnership"), which, in turn, invests all or substantially all of its capita

ich are not deductible by a noncorporate taxpayer in calculating its alternative minimum tax liability. Pursuant to Temporary Regulations issued by the Treasury Department, these limitations on deductibility should not apply to a noncorporate Limited Partner's share of the expenses of the Master Partnership to the ext

ty company that was formed in 1994. The General Partner also serves as the sole general partner of Millennium USA, Millennium Strategic Capital and Millennium Offshore Intermediate. The General Partner is considered to be under the ultimate control of Israel Englander. The business address and telephone number of the General