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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
ts investments from outside investors and primarily invests its capital in the Master Partnership (or its underlying strategies) indirectly through Millennium Offshore Intermediate, L.P., a Cayman Islands exempted limited partnership (the "Intermediate Partnership"), which, in turn, invests all or substantially all of its capi
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
hip"). Millennium International, Ltd. ("Millennium International"), accepts investments from outside investors and primarily invests its capital in Millennium Offshore Intermediate, L.P., a Cayman Islands exempted limited partnership (the "Intermediate Partnership"), which, in turn, invests all or substantially all of its capi
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
hip"). Millennium International, Ltd. ("Millennium International"), accepts investments from outside investors and primarily invests its capital in Millennium Offshore Intermediate, •., a Cayman Islands exempted limited partnership (the "Intermediate Partnership"), which, in turn, invests all or substantially all of its capita
Entities connected to both Non-U.S. Investments and Millennium Offshore Intermediate

United States
LOCATION
the Internal Revenue Service
ORGANIZATIONCayman
LOCATION
U.S. Treasury
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONErnst & Young LLP
ORGANIZATIONThe Master Partnership's Organization
ORGANIZATION
New York
LOCATIONMillennium Partners
ORGANIZATION
Millennium
ORGANIZATIONMillennium USA's
LOCATIONManagement of Millennium USA
ORGANIZATIONMillennium International, Ltd.
ORGANIZATIONTrigger Event
ORGANIZATIONthe District of Columbia
LOCATIONNO OFFERING LITERATURE OR ADVERTISING
ORGANIZATION
Paul Volcker
PERSONCustodian
ORGANIZATION
UBS AG
ORGANIZATIONthe Federal Reserve System
ORGANIZATION