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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
Investment Program and Strategy 26 Use of Proceeds by Millennium USA 26 Millennium USA's Organization, Management, Structure, and Operations 26 Management of Millennium USA 32 The Administrator 33 Fees and Expenses Relating to Millennium USA 34 Allocation of Gains and Losses 36 Outline of the Partnership Agreemen
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
ment 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 Gains and Losses 1-36 Outline of the Partnership
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
ment 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 Gains and Losses 1-36 Outline of the Partnership
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Mutual Connections (119)
Entities connected to both Non-U.S. Investments and Management of Millennium USA
United States
LOCATION5 w/ Non-U.S.·5 w/ Management
Cayman
LOCATION4 w/ Non-U.S.·6 w/ Management
New York
LOCATION3 w/ Non-U.S.·6 w/ Management
Trigger Event
ORGANIZATION3 w/ Non-U.S.·6 w/ Management
Millennium Partners
ORGANIZATION3 w/ Non-U.S.·6 w/ Management
Ernst & Young LLP
ORGANIZATION3 w/ Non-U.S.·6 w/ Management
Millennium USA's
LOCATION3 w/ Non-U.S.·6 w/ Management
Millennium
ORGANIZATION3 w/ Non-U.S.·6 w/ Management
The Master Partnership's Organization
ORGANIZATION3 w/ Non-U.S.·6 w/ Management
the U.S. Investment Company Act
ORGANIZATION3 w/ Non-U.S.·6 w/ Management
the Internal Revenue Service
ORGANIZATION4 w/ Non-U.S.·5 w/ Management
Millennium International, Ltd.
ORGANIZATION3 w/ Non-U.S.·6 w/ Management
U.S. Treasury
ORGANIZATION3 w/ Non-U.S.·6 w/ Management
Millennium Offshore Intermediate
ORGANIZATION3 w/ Non-U.S.·5 w/ Management
Master-Feeder Relationship
ORGANIZATION2 w/ Non-U.S.·5 w/ Management
Schulte Roth & Zabel LLP
ORGANIZATION3 w/ Non-U.S.·4 w/ Management
Capital Structure
ORGANIZATION2 w/ Non-U.S.·5 w/ Management
Organization, Management
ORGANIZATION3 w/ Non-U.S.·4 w/ Management
Independent Public Accountants
ORGANIZATION2 w/ Non-U.S.·5 w/ Management
Keogh
ORGANIZATION2 w/ Non-U.S.·5 w/ Management