Epstein Secrets

und, either directly or through flow through entities treated as transparent for U.S. federal income tax purposes, lack economic substance. Certain Non-U.S. Investments. Pursuant to various "anti-deferral" provisions of the Code (the "Subpart F" and PFIC provisions), any investments by the Fund in certain foreign co

Fund carried on outside the Cayman Islands. The Fund is a regulated mutual fund for the purposes of the Mutual Funds Law and is registered with the Cayman Islands Monetary Authority (-MA") pursuant to section 4(3) of that law. This offering memorandum has been filed with CIMA. Such registration does n

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

. Millennium USA carries out its investment and trading activities primarily by investing in Millennium Partners, L.P. (the "Master Partnership"), a Cayman DOC ID- 29147063.5 CONFIDENTIAL UBSTERRAMAR00003927 EFTA00239259 FOR EXISTING INVESTOR USE ONLY Islands exempted limited partnership initially

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

. Millennium USA carries out its investment and trading activities primarily by investing in Millennium Partners, L.P. (the "Master Partnership"), a Cayman Islands exempted limited partnership initially organized in 1989 as a Delaware limited partnership, but it may also trade and invest part of its ca

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

gy"). Millennium USA carries out its investment and trading activities primarily by investing in Millennium Partners, (the "Master Partnership"), a Cayman Islands exempted limited partnership initially organized in 1989 as a Delaware limited partnership, but it may also trade and invest part of its ca