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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
in Millennium USA does not constitute a complete investment program and (iii) that fully understand and are willing to assume the risks involved in Millennium USA's investment program. Millennium USA's investment practices, by their nature, may be considered to involve a substantial degree of risk. (See "Certai
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
n Millennium USA does not constitute a complete investment program, and (iii) that fully understand and are willing to assume the risks involved in Millennium USA's investment program. Millennium USA's investment practices, by their nature, may be considered to involve a substantial degree of risk. (See "Certa
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
n Millennium USA does not constitute a complete investment program, and (iii) that fully understand and are willing to assume the risks involved in Millennium USA's investment program. Millennium USA's investment practices, by their nature, may be considered to involve a substantial degree of risk. (See "Certa
Entities connected to both Non-U.S. Investments and Millennium USA's

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