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d in the name of a custodian with a sub- custodian or in a securities depository, clearing agency or omnibus customer account of such custodian. The Custodian's principal business address is 240 Greenwich Street, New York, New York 10286. The AlphaKeys Fund has also entered into an Escrow Agreement with BN
is urged to consult with its own tax advisor regarding the U.S. and non-U.S. tax treatment of an investment in the AlphaKeys Fund. Implications of Non-U.S. Investments Certain non-U.S. investments of the Underlying Fund and the Underlying Master Fund, including investments in "controlled foreign corporations" and
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that securities are held in the name of a custodian in a securities depository, clearing agency or omnibus customer account of such custodian. The Custodian's principal business address is 8800 Tinicum Boulevard, 4th Floor, Philadelphia, Pennsylvania 19153. ML281817-MAXWELL -56- CONFIDENTIAL UBSTERRAM
is urged to consult with its own tax advisor regarding the U.S. and non-U.S. tax treatment of an investment in the AlphaKeys Fund. Implications of Non-U.S. Investments Certain non-U.S. investments of the Underlying Fund and the Underlying Master Fund, including investments in "controlled foreign corporations" and
2 mentions1 same-page
Page ?Same page
that securities are held in the name of a custodian in a securities depository, clearing agency or omnibus customer account of such custodian. The Custodian's principal business address is 8800 Tinicum Boulevard, 4th Floor, Philadelphia, Pennsylvania 19153. MAXWELL -56- CONFIDENTIAL UBSTERRAMAR0000126
is urged to consult with its own tax advisor regarding the U.S. and non-U.S. tax treatment of an investment in the AlphaKeys Fund. Implications of Non-U.S. Investments Certain non-U.S. investments of the Underlying Fund and the Underlying Master Fund, including investments in "controlled foreign corporations" and
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Mutual Connections (117)
Entities connected to both Custodian and Non-U.S. Investments
United States
LOCATION3 w/ Custodian·5 w/ Non-U.S.
the District of Columbia
LOCATION3 w/ Custodian·4 w/ Non-U.S.
Cayman
LOCATION3 w/ Custodian·4 w/ Non-U.S.
the Internal Revenue Service
ORGANIZATION3 w/ Custodian·4 w/ Non-U.S.
Treatment as Partnership
ORGANIZATION3 w/ Custodian·3 w/ Non-U.S.
Importance of Obtaining Professional Advice
ORGANIZATION3 w/ Custodian·3 w/ Non-U.S.
the UBSFS Advisory Program
ORGANIZATION3 w/ Custodian·3 w/ Non-U.S.
THE ALPHAKEYS FUND IN LIGHT
ORGANIZATION3 w/ Custodian·3 w/ Non-U.S.
Independent Auditors and Legal Counsel
ORGANIZATION3 w/ Custodian·3 w/ Non-U.S.
Ropes & Gray LLP's
ORGANIZATION3 w/ Custodian·3 w/ Non-U.S.
NO OFFERING LITERATURE OR ADVERTISING
ORGANIZATION3 w/ Custodian·3 w/ Non-U.S.
Management of Millennium USA
ORGANIZATION3 w/ Custodian·3 w/ Non-U.S.
The Master Partnership's Organization
ORGANIZATION3 w/ Custodian·3 w/ Non-U.S.
Organization, Management, Structure and Operations
ORGANIZATION3 w/ Custodian·3 w/ Non-U.S.
Organization, Management
ORGANIZATION3 w/ Custodian·3 w/ Non-U.S.
Millennium Offshore Intermediate
ORGANIZATION3 w/ Custodian·3 w/ Non-U.S.
the "Intermediate Partnership
ORGANIZATION3 w/ Custodian·3 w/ Non-U.S.
Different Returns Among Investors
ORGANIZATION3 w/ Custodian·3 w/ Non-U.S.
the Master Partnership or Portfolio Managers
ORGANIZATION3 w/ Custodian·3 w/ Non-U.S.
IE
Israel A. Englander
PERSON3 w/ Custodian·3 w/ Non-U.S.