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ut regard to the length of time held. Any active short-term trading of the Fund will increase its rate of turnover and related transaction expenses. Non-U.S. Investments The Fund may invest a portion of Fund’s total committed capital in the securities of issuers that are organized outside of the U.S. and Canada. Inve
CONFIDENTIAL HOUSE_OVERSIGHT_024083 X. CERTAIN TAX AND ERISA CONSIDERATIONS IN ACCORDANCE WITH U.S. TREASURY REGULATIONS GOVERNING PRACTICE BEFORE THE INTERNAL REVENUE SERVICE (CIRCULAR 230), LEGAL COUNSEL TO THE FUND HEREBY INFORMS INVESTORS THAT (A) THE INFORMATION BELOW (OR OTHERWISE CONTAINED IN THIS DOCUMENT) IS NOT IN
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
uld result to Investors in the AlphaKeys Fund. The AlphaKeys Fund may, from time to time, report tax positions that may be subject to challenge by the Internal Revenue Service (the "IRS"). If the IRS challenges such a position and is successful, there may be substantial retroactive taxes, plus interest and possibly penalti
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
of the Administrator's affiliates or employees for tax advice in connection with its investment. To ensure compliance with requirements imposed by the Internal Revenue Service (the "IRS") in Circular 230, you are hereby informed that any tax advice contained in this Memorandum (i) is written in connection with the promoti
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
of the Administrator's affiliates or employees for tax advice in connection with its investment. To ensure compliance with requirements imposed by the Internal Revenue Service (the "IRS") in Circular 230, you are hereby informed that any tax advice contained in this Memorandum (i) is written in connection with the promoti
Entities connected to both Non-U.S. Investments and the Internal Revenue Service

Ghislaine Maxwell
PERSON
FDIC
ORGANIZATION
Federal Reserve
ORGANIZATION
United States
LOCATION
New York
LOCATION
U.S. Treasury
ORGANIZATIONthe District of Columbia
LOCATION
Philadelphia
LOCATIONthe U.S. Investment Company Act
ORGANIZATION
Cayman Islands
LOCATIONCayman
LOCATIONKeogh
ORGANIZATION
the Cayman Islands
LOCATION
UBS AG
ORGANIZATIONthe Federal Reserve System
ORGANIZATIONthe New York Stock Exchange
ORGANIZATION
Millennium
ORGANIZATIONTrigger Event
ORGANIZATIONMillennium USA's
LOCATIONMillennium International, Ltd.
ORGANIZATION