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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
all years of the Underlying Fund and the Underlying Master Fund unless revoked with the consent of the IRS. As a result of the Underlying Fund's and the Underlying Master Fund's mark-to-market election, the AlphaKeys Fund will generally be required to recognize ordinary gain or loss on all of the securities held by the Unde
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
ing obligations in non-U.S. jurisdictions, including withholding taxes on dividends, interest and proceeds. In particular, the Underlying Fund's and the Underlying Master Fund's non- U.S. investments may cause some of the income or gains of the AlphaKeys Fund to be subject to withholding or other taxes of non-U.S. jurisdicti
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
ing obligations in non-U.S. jurisdictions, including withholding taxes on dividends, interest and proceeds. In particular, the Underlying Fund's and the Underlying Master Fund's non- U.S. investments may cause some of the income or gains of the AlphaKeys Fund to be subject to withholding or other taxes of non-U.S. jurisdicti
Entities connected to both Custodian and the Underlying Master Fund's
This Confidential Memorandum
ORGANIZATION
United States
LOCATION
Paul Volcker
PERSON
U.S. Treasury
ORGANIZATION
UBS AG
ORGANIZATION
Millennium
ORGANIZATIONthe Federal Reserve System
ORGANIZATIONNon-U.S. Investments
ORGANIZATION
the Internal Revenue Service
ORGANIZATION
New York
LOCATIONthe District of Columbia
LOCATIONErnst & Young LLP
ORGANIZATIONClasses of Interests
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONSchulte Roth & Zabel LLP
ORGANIZATIONAnti-Money Laundering
ORGANIZATIONCayman
LOCATIONTrigger Event
ORGANIZATIONnon-U.S. Investors
ORGANIZATIONAdministrative Services
ORGANIZATION