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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
nvestor (the "Investor Application"). -42- CONFIDENTIAL UBSTERRAMAR00003904 EFTA00239236 FOR EXISTING INVESTOR USE ONLY VL TAX ASPECTS Certain Material United States Federal Income Tax Considerations The following is a general summary of certain U.S. federal income tax considerations relating to an investment in
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
prospective Investor (the "Investor Application"). ML281817-MAXWELL -39- CONFIDENTIAL UBSTERRAMAR00002305 EFTA00237861 VI. TAX ASPECTS Certain Material United States Federal Income Tax Considerations To ensure compliance with requirements imposed by the IRS in Circular 230, you are hereby informed that any tax a
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
by each prospective Investor (the "Investor Application"). MAXWELL -39- CONFIDENTIAL UBSTERRAMAR00001252 EFTA00236898 VI. TAX ASPECTS Certain Material United States Federal Income Tax Considerations To ensure compliance with requirements imposed by the IRS in Circular 230, you are hereby informed that any tax a
Entities connected to both Millennium and Material United States

Ghislaine Maxwell
PERSON
United States
LOCATION
New York
LOCATIONCayman
LOCATIONErnst & Young LLP
ORGANIZATION
UBS AG
ORGANIZATIONMillennium USA's
LOCATION
the Internal Revenue Service
ORGANIZATIONMillennium International, Ltd.
ORGANIZATIONTrigger Event
ORGANIZATIONBNY Mellon Alternative Investment Services
ORGANIZATIONManagement of Millennium USA
ORGANIZATIONAdministrative Services
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
U.S. Treasury
ORGANIZATIONThe Master Partnership's Organization
ORGANIZATIONMillennium Partners
ORGANIZATION
Federal Reserve
ORGANIZATIONRelated-Party Transactions
ORGANIZATIONMillennium Offshore Intermediate
ORGANIZATION