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nium USA are referred to herein as the "Limited Partners." The Limited Partners, together with Millennium Management LLC, the general partner of Millennium USA ("Millennium Management"), are referred to herein as the "Partners." Millennium Management is also the general partner of the Master Partner
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
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e the AlphaKeys Fund is regarded as doing business or earning income (directly or indirectly). See "Certain Tax Matters Relating to an Investment in Millennium ML281817-MAXWELL -32- CONFIDENTIAL UBSTERRAMAR00002298 EFTA00237854 USA" and "Certain Tax Matters Relating to the Master Partnership" in Part O
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
e the AlphaKeys Fund is regarded as doing business or earning income (directly or indirectly). See "Certain Tax Matters Relating to an Investment in Millennium MAXWELL -32- CONFIDENTIAL UBSTERRAMAR00001245 EFTA00236891 USA" and "Certain Tax Matters Relating to the Master Partnership" in Part One of the
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 (119)
Entities connected to both Millennium and Non-U.S. Investments
Ghislaine Maxwell
PERSON30 w/ Millennium·2 w/ Non-U.S.
United States
LOCATION15 w/ Millennium·5 w/ Non-U.S.
New York
LOCATION12 w/ Millennium·3 w/ Non-U.S.
Cayman
LOCATION10 w/ Millennium·4 w/ Non-U.S.
Ernst & Young LLP
ORGANIZATION9 w/ Millennium·3 w/ Non-U.S.
UBS AG
ORGANIZATION8 w/ Millennium·3 w/ Non-U.S.
the Internal Revenue Service
ORGANIZATION7 w/ Millennium·4 w/ Non-U.S.
Millennium USA's
LOCATION7 w/ Millennium·3 w/ Non-U.S.
Millennium International, Ltd.
ORGANIZATION7 w/ Millennium·3 w/ Non-U.S.
the U.S. Investment Company Act
ORGANIZATION6 w/ Millennium·3 w/ Non-U.S.
Millennium Partners
ORGANIZATION6 w/ Millennium·3 w/ Non-U.S.
The Master Partnership's Organization
ORGANIZATION6 w/ Millennium·3 w/ Non-U.S.
Trigger Event
ORGANIZATION6 w/ Millennium·3 w/ Non-U.S.
Management of Millennium USA
ORGANIZATION6 w/ Millennium·3 w/ Non-U.S.
U.S. Treasury
ORGANIZATION6 w/ Millennium·3 w/ Non-U.S.
Administrative Services
ORGANIZATION6 w/ Millennium·3 w/ Non-U.S.
BNY Mellon Alternative Investment Services
ORGANIZATION6 w/ Millennium·3 w/ Non-U.S.
Related-Party Transactions
ORGANIZATION6 w/ Millennium·2 w/ Non-U.S.
Federal Reserve
ORGANIZATION6 w/ Millennium·2 w/ Non-U.S.
Occidental College
ORGANIZATION6 w/ Millennium·2 w/ Non-U.S.