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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
n Investor other than its investment in the AlphaKeys Fund may affect the tax consequences to such Investor of an investment in the AlphaKeys Fund. Treatment as Partnership. It is intended that the AlphaKeys Fund will be treated as a partnership for U.S. federal income tax purposes and not as an association or "publicly
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
nvestor other than its investment in the Alpha Keys Fund may affect the tax consequences to such Investor of an investment in the Alpha Keys Fund. Treatment as Partnership. It is intended that the Alpha Keys Fund will be treated as a partnership for U.S. federal income tax purposes and not as an association or "public
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
nvestor other than its investment in the Alpha Keys Fund may affect the tax consequences to such Investor of an investment in the Alpha Keys Fund. Treatment as Partnership. It is intended that the Alpha Keys Fund will be treated as a partnership for U.S. federal income tax purposes and not as an association or "public
Entities connected to both Millennium and Treatment as Partnership

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