3
Shared Docs
3
Same-Page
3 / 3
Mentions
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
ip") and may also invest through separate legal entities directly in the Master Partnership's underlying strategies. In addition to Millennium USA, Millennium International, Ltd. ("Millennium International") also accepts investments from outside investors and primarily invests its capital in the Master Partnership (or its un
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 accepts investments from outside investors and primarily invests its capital in Millennium Partners, L.P. (the "Master Partnership"). Millennium International, Ltd. ("Millennium International"), accepts investments from outside investors and primarily invests its capital in Millennium Offshore Intermediate, L.P
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 accepts investments from outside investors and primarily invests its capital in Millennium Partners, (the "Master Partnership"). Millennium International, Ltd. ("Millennium International"), accepts investments from outside investors and primarily invests its capital in Millennium Offshore Intermediate, •.,
Entities connected to both Non-U.S. Investments and Millennium International, Ltd.

United States
LOCATION
Millennium
ORGANIZATIONCayman
LOCATIONMillennium USA's
LOCATION
the Internal Revenue Service
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
U.S. Treasury
ORGANIZATIONTrigger Event
ORGANIZATIONMillennium Partners
ORGANIZATION
New York
LOCATIONThe Master Partnership's Organization
ORGANIZATIONManagement of Millennium USA
ORGANIZATIONErnst & Young LLP
ORGANIZATIONMillennium Offshore Intermediate
ORGANIZATIONSchulte Roth & Zabel LLP
ORGANIZATION
Ghislaine Maxwell
PERSONCapital Structure
ORGANIZATIONMaster-Feeder Relationship
ORGANIZATIONGlobeOp Financial Services
ORGANIZATIONOrganization, Management
ORGANIZATION