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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
nderlying Fund, which is subject to the withdrawal terms of the Underlying Fund and may be delayed or suspended altogether. See "Millennium USA's Organization, Management, Structure, and Operations" in Part One of the Underlying Fund Memorandum. The Administrator may determine to satisfy a withdrawal request in full, without a
2 mentions1 same-page
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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
Interests of Millennium USA 1-24 Millennium USA's Investment Program and Strategy 1-26 Use of Proceeds by Millennium USA I-26 Millennium USA's Organization, Management, Structure, and Operations 1-26 Management of Millennium USA I-33 The Administrator I-33 Fees and Expenses Relating to Millennium USA 1-35 Allocation of
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
Interests of Millennium USA 1-24 Millennium USA's Investment Program and Strategy 1-26 Use of Proceeds by Millennium USA I-26 Millennium USA's Organization, Management, Structure, and Operations 1-26 Management of Millennium USA I-33 The Administrator I-33 Fees and Expenses Relating to Millennium USA 1-35 Allocation of
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Mutual Connections (118)
Entities connected to both Non-U.S. Investments and Organization, Management, Structure
United States
LOCATION5 w/ Non-U.S.·3 w/ Organization,
Cayman
LOCATION4 w/ Non-U.S.·4 w/ Organization,
New York
LOCATION3 w/ Non-U.S.·4 w/ Organization,
Millennium Partners
ORGANIZATION3 w/ Non-U.S.·4 w/ Organization,
Trigger Event
ORGANIZATION3 w/ Non-U.S.·4 w/ Organization,
the District of Columbia
LOCATION4 w/ Non-U.S.·3 w/ Organization,
Millennium
ORGANIZATION3 w/ Non-U.S.·4 w/ Organization,
The Master Partnership's Organization
ORGANIZATION3 w/ Non-U.S.·4 w/ Organization,
Ernst & Young LLP
ORGANIZATION3 w/ Non-U.S.·4 w/ Organization,
Management of Millennium USA
ORGANIZATION3 w/ Non-U.S.·4 w/ Organization,
U.S. Treasury
ORGANIZATION3 w/ Non-U.S.·4 w/ Organization,
the U.S. Investment Company Act
ORGANIZATION3 w/ Non-U.S.·4 w/ Organization,
Millennium International, Ltd.
ORGANIZATION3 w/ Non-U.S.·4 w/ Organization,
Schulte Roth & Zabel LLP
ORGANIZATION3 w/ Non-U.S.·4 w/ Organization,
the Internal Revenue Service
ORGANIZATION4 w/ Non-U.S.·3 w/ Organization,
Millennium USA's
LOCATION3 w/ Non-U.S.·4 w/ Organization,
Organization, Management
ORGANIZATION3 w/ Non-U.S.·4 w/ Organization,
Independent Auditors and Legal Counsel
ORGANIZATION3 w/ Non-U.S.·3 w/ Organization,
non-U.S. Investors
ORGANIZATION3 w/ Non-U.S.·3 w/ Organization,
Administrative Services
ORGANIZATION3 w/ Non-U.S.·3 w/ Organization,