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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
nd Expenses" in Part Two of the Underlying Fund Memorandum for further discussion of the Underlying Fund's and Underlying Master Fund's expenses. BNY Mellon Alternative Investment Services (the "Sub- Administrator") performs certain administration, accounting and investor services for the AlphaKeys Fund and other investment funds spon
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
Part Two of the Underlying Fund Memorandum for further discussion of the Underlying Fund's and Underlying Master Fund's expenses. OTHER EXPENSES BNY Mellon Alternative Investment Services (the "Sub-. Administrator") performs certain administration, accounting and investor services for the AlphaKeys Fund and other investment funds sp
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 Underlying Fund Memorandum for further discussion of the Underlying Fund's and Underlying Master Fund's expenses. OTHER EXPENSES MEVIAXWELL BNY Mellon Alternative Investment Services (the "Sub-. Administrator") performs certain administration, accounting and investor services for the AlphaKeys Fund and other investment funds sp
Entities connected to both Non-U.S. Investments and BNY Mellon Alternative Investment Services

United States
LOCATION
Millennium
ORGANIZATIONCayman
LOCATIONthe District of Columbia
LOCATION
Ghislaine Maxwell
PERSON
the Internal Revenue Service
ORGANIZATIONThis Confidential Memorandum
ORGANIZATION
Paul Volcker
PERSON
U.S. Treasury
ORGANIZATIONCustodian
ORGANIZATION
UBS AG
ORGANIZATIONthe Federal Reserve System
ORGANIZATION
New York
LOCATIONErnst & Young LLP
ORGANIZATIONClasses of Interests
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONSchulte Roth & Zabel LLP
ORGANIZATIONAnti-Money Laundering
ORGANIZATIONTrigger Event
ORGANIZATIONnon-U.S. Investors
ORGANIZATION