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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
of interests (e.g., currency hedges). As an investor in the Underlying Fund, the AlphaKeys Fund may be subject to these same risks with respect to the Underlying Fund Interests. Similarly, although Investors may hold separate classes, sub-classes or series of Interests, the AlphaKeys Fund is a single legal entity and its c
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
ies of shares (e.g., currency hedges). As an investor in the Underlying Fund, the AlphaKeys Fund may be subject to these same risks with respect to the Underlying Fund Interests. Idle Funds. The AlphaKeys Fund may retain a portion of the subscription proceeds that will not be invested in the Underlying Fund, to meet certain
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
ies of shares (e.g., currency hedges). As an investor in the Underlying Fund, the AlphaKeys Fund may be subject to these same risks with respect to the Underlying Fund Interests. Idle Funds. The AlphaKeys Fund may retain a portion of the subscription proceeds that will not be invested in the Underlying Fund, to meet certain
Entities connected to both Non-U.S. Investments and the Underlying Fund Interests

United States
LOCATIONthe District of Columbia
LOCATION
the Internal Revenue Service
ORGANIZATIONCayman
LOCATION
UBS AG
ORGANIZATION
Millennium
ORGANIZATIONthe Federal Reserve System
ORGANIZATIONThis Confidential Memorandum
ORGANIZATION
Paul Volcker
PERSON
U.S. Treasury
ORGANIZATIONCustodian
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
ORGANIZATIONAdministrative Services
ORGANIZATION