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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
ications for holders of Offered Interests. General Partner; Incentive The general partner of Millennium USA is Millennium Allocation: Management. Israel A. Englander is currently the controlling trustee of Millennium Group Management LLC (formerly, Millennium International Management GP LLC), the managing membe
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
Withdrawal Right upon a Trigger Event.") General Partner; Incentive The general partner of Millennium USA is Millennium Allocation: Management. Israel A. Englander is the managing member of Millennium Management. Millennium Management also serves as the general partner of the Master Partnership. See "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
Withdrawal Right upon a Trigger Event.") General Partner; Incentive The general partner of Millennium USA is Millennium Allocation: Management. Israel A. Englander is the managing member of Millennium Management. Millennium Management also serves as the general partner of the Master Partnership. See "The Mas
Entities connected to both Non-U.S. Investments and Israel A. Englander

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