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de at this time, and upon a particular Member's individual circumstances. No advance rulings have been or will be sought by the AlphaKeys Fund from the Internal Revenue Service (the "IRS") regarding any matter discussed in this Memorandum. IN VIEW OF THE FOREGOING, EACH PROSPECTIVE INVESTOR SHOULD CONSULT ITS OWN TAX ADVI
the amount to be contributed by a Dollar Partner, the General Partner will generally convert U.S. dollars into the relevant currency of a proposed Investment and (ii) all calculations under the Partnership Agreement, including calculations of Management Fees and Carried Interest, will be done in Euros ir
the income taxation of Millennium USA and its Partners which should be considered by a Limited Partner. Millennium USA has not sought a ruling from the Internal Revenue Service (the "Service") or any other federal, state or local agency with respect to any of the tax issues affecting Millennium USA, nor has it obtained an
rests held by them and their associates in each prescribed person or approved company (as the case may be). Limited Partners may be required by the Investment Manager and/or MCM Singapore to disclose such status and computation to the Investment Manager and MCM Singapore from time to time. The taxation of
the income taxation of Millennium USA and its Partners which should be considered by a Limited Partner. Millennium USA has not sought a ruling from the Internal Revenue Service (the "Service") or any other federal, state or local agency with respect to any of the tax issues affecting Millennium USA, nor has it obtained an
rests held by them and their associates in each prescribed person or approved company (as the case may be). Limited Partners may be required by the Investment Manager and/or MCM Singapore to disclose such status and computation to the Investment Manager and MCM Singapore from time to time. The taxation of
Entities connected to both the Internal Revenue Service and Investment

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