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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
the laws of the states and jurisdictions where the offering will be made. The AlphaKeys Fund will not be registered as an investment company under the U.S. Investment Company Act of 1940, as amended (the "1940 Act"). There is no public market for the Class B Interests and no such market is expected to develop in the future.
2 mentions1 same-page
Page ?Same page
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
the laws of the states and jurisdictions where the offering will be made. The AlphaKeys Fund will not be registered as an investment company under the U.S. Investment Company Act of 1940, as amended (the "1940 Act"). There is no public market for the Interests and no such market is expected to develop in the future. The Inte
2 mentions1 same-page
Page ?Same page
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
the laws of the states and jurisdictions where the offering will be made. The AlphaKeys Fund will not be registered as an investment company under the U.S. Investment Company Act of 1940, as amended (the "1940 Act"). There is no public market for the Interests and no such market is expected to develop in the future. The Inte
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Mutual Connections (119)
Entities connected to both Non-U.S. Investments and the U.S. Investment Company Act
United States
LOCATION5 w/ Non-U.S.·31 w/ the
Ghislaine Maxwell
PERSON2 w/ Non-U.S.·25 w/ the
Cayman Islands
LOCATION2 w/ Non-U.S.·25 w/ the
the Internal Revenue Service
ORGANIZATION4 w/ Non-U.S.·21 w/ the
Cayman
LOCATION4 w/ Non-U.S.·15 w/ the
the Cayman Islands
LOCATION2 w/ Non-U.S.·14 w/ the
the District of Columbia
LOCATION4 w/ Non-U.S.·11 w/ the
Keogh
ORGANIZATION2 w/ Non-U.S.·13 w/ the
Paul Volcker
PERSON3 w/ Non-U.S.·9 w/ the
New York
LOCATION3 w/ Non-U.S.·9 w/ the
non-U.S. Investors
ORGANIZATION3 w/ Non-U.S.·8 w/ the
Millennium USA's
LOCATION3 w/ Non-U.S.·6 w/ the
Trigger Event
ORGANIZATION3 w/ Non-U.S.·6 w/ the
Management of Millennium USA
ORGANIZATION3 w/ Non-U.S.·6 w/ the
Millennium
ORGANIZATION3 w/ Non-U.S.·6 w/ the
U.S. Treasury
ORGANIZATION3 w/ Non-U.S.·6 w/ the
Millennium Partners
ORGANIZATION3 w/ Non-U.S.·6 w/ the
Ernst & Young LLP
ORGANIZATION3 w/ Non-U.S.·6 w/ the
Classes of Interests
ORGANIZATION3 w/ Non-U.S.·6 w/ the
The Master Partnership's Organization
ORGANIZATION3 w/ Non-U.S.·6 w/ the