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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
atters Relating to an Investment in Millennium USA" and "Certain Tax Matters Relating to the Master Partnership" in the Underlying Fund Memorandum. Importance of Obtaining Professional Advice The foregoing analysis is not intended as a substitute for careful tax planning. Accordingly, prospective Investors in the AlphaKeys Fund are stron
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
tters Relating to an Investment in Millennium USA" and "Certain Tax Matters Relating to the Master Partnership" in the Underlying Fund Memorandum. Importance of Obtaining Professional Advice The foregoing analysis is not intended as a substitute for careful tax planning. Accordingly, prospective Investors in the AlphaKeys Fund are stron
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
tters Relating to an Investment in Millennium USA" and "Certain Tax Matters Relating to the Master Partnership" in the Underlying Fund Memorandum. Importance of Obtaining Professional Advice The foregoing analysis is not intended as a substitute for careful tax planning. Accordingly, prospective Investors in the AlphaKeys Fund are stron
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Mutual Connections (117)
Entities connected to both Non-U.S. Investments and Importance of Obtaining Professional Advice
United States
LOCATION5 w/ Non-U.S.·3 w/ Importance
the District of Columbia
LOCATION4 w/ Non-U.S.·3 w/ Importance
the Internal Revenue Service
ORGANIZATION4 w/ Non-U.S.·3 w/ Importance
Cayman
LOCATION4 w/ Non-U.S.·3 w/ Importance
UBS AG
ORGANIZATION3 w/ Non-U.S.·3 w/ Importance
Millennium
ORGANIZATION3 w/ Non-U.S.·3 w/ Importance
the Federal Reserve System
ORGANIZATION3 w/ Non-U.S.·3 w/ Importance
This Confidential Memorandum
ORGANIZATION3 w/ Non-U.S.·3 w/ Importance
Paul Volcker
PERSON3 w/ Non-U.S.·3 w/ Importance
U.S. Treasury
ORGANIZATION3 w/ Non-U.S.·3 w/ Importance
Custodian
ORGANIZATION3 w/ Non-U.S.·3 w/ Importance
New York
LOCATION3 w/ Non-U.S.·3 w/ Importance
Ernst & Young LLP
ORGANIZATION3 w/ Non-U.S.·3 w/ Importance
Classes of Interests
ORGANIZATION3 w/ Non-U.S.·3 w/ Importance
the U.S. Investment Company Act
ORGANIZATION3 w/ Non-U.S.·3 w/ Importance
Schulte Roth & Zabel LLP
ORGANIZATION3 w/ Non-U.S.·3 w/ Importance
Anti-Money Laundering
ORGANIZATION3 w/ Non-U.S.·3 w/ Importance
Trigger Event
ORGANIZATION3 w/ Non-U.S.·3 w/ Importance
non-U.S. Investors
ORGANIZATION3 w/ Non-U.S.·3 w/ Importance
Administrative Services
ORGANIZATION3 w/ Non-U.S.·3 w/ Importance