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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 in Millennium USA, or their engaging directly, or indirectly through an investment in Millennium USA, in investment strategies of the types which the Master Partnership or Portfolio Managers may utilize from time- to-time (e.g., leverage, the purchase and sale of options and limited diversification). While Millennium USA believes the Mas
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 in Millennium USA, in investment ML281817-MAXWELL I-23 CONFIDENTIAL UBSTERRAMAR00002353 EFTA00237909 strategies of the types which the Master Partnership or Portfolio Managers may utilize from time-to-time (e.g., leverage, the purchase and sale of options and limited diversification). While Millennium USA believes the Mas
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
ugh an investment in Millennium USA, in investment .=-MAXWELL I-23 CONFIDENTIAL UBSTERRAMAR00001300 EFTA00236946 strategies of the types which the Master Partnership or Portfolio Managers may utilize from time-to-time (e.g., leverage, the purchase and sale of options and limited diversification). While Millennium USA believes the Mas
Entities connected to both Non-U.S. Investments and the Master Partnership or Portfolio Managers

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