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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
N RELATING TO MILLENNIUM PARTNERS, L.P. Sununary of Part Two of the Confidential Memorandum II-1 The Fund's Investment Program and Strategy II-8 The Master Partnership's Organization 11-9 Certain Risk Factors Relating to an Investment in the Fund II-11 The Fund's Management. Structure and Operations II-46 The Fund's Investm
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
ON RELATING TO MILLENNIUM PARTNERS, L.P. Summary of Part Two of the Confidential Memorandum II-1 The Fund's Investment Program and Strategy 11-8 The Master Partnership's Organization II-9 Certain Risk Factors Relating to an Investment in the Fund II-11 The Fund's Management, Structure and Operations II-37 The Fund's Investme
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
TION RELATING TO MILLENNIUM PARTNERS, M. Summary of Part Two of the Confidential Memorandum II-1 The Fund's Investment Program and Strategy 11-8 The Master Partnership's Organization II-9 Certain Risk Factors Relating to an Investment in the Fund II-11 The Fund's Management, Structure and Operations II-37 The Fund's Investme
Entities connected to both Non-U.S. Investments and The Master Partnership's Organization

United States
LOCATIONCayman
LOCATION
New York
LOCATIONTrigger Event
ORGANIZATIONMillennium Partners
ORGANIZATIONErnst & Young LLP
ORGANIZATIONMillennium USA's
LOCATION
Millennium
ORGANIZATIONManagement of Millennium USA
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONMillennium International, Ltd.
ORGANIZATION
U.S. Treasury
ORGANIZATIONMillennium Offshore Intermediate
ORGANIZATIONMaster-Feeder Relationship
ORGANIZATIONSchulte Roth & Zabel LLP
ORGANIZATIONCapital Structure
ORGANIZATIONOrganization, Management
ORGANIZATIONIndependent Public Accountants
ORGANIZATIONKeogh
ORGANIZATION