Epstein Secrets

46FF-2840-40a6-8DDA-07ED9F769640 forth in Treasury Regulation section §1.704-2(F)(2) and (3), and to any exceptions provided by the Commissioner of the Internal Revenue Service pursuant to Treasury Regulation section §1.704-2(f)(5), provided that if the Partnership has any discretion as to an exception provided pursuant to

ntemplated by this Agreement (except to the extent such information is relevant to U.S. tax structure or tax treatment of such transactions). 14.2 Anti-Money Laundering. (a) Each Limited Partner hereby represents and covenants to ensure that: (i) none of the monies that such Limited Partner will contribute to the

hat, although the Partnership intends to adopt positions it believes are in accord with current interpretations of the U.S. federal income tax laws, the Internal Revenue Service ("IRS") may not agree with the tax positions taken by the Partnership and that, if challenged by the IRS, the Partnership's tax positions might not

nt upon or approved the terms or merits of this document. There is no investment compensation scheme available to investors in the Cayman Islands. Anti-Money Laundering — Cayman Islands In order to comply with regulations aimed at the prevention of money laundering in any applicable jurisdictions, the Partnership m

uld result to Investors in the AlphaKeys Fund. The AlphaKeys Fund may, from time to time, report tax positions that may be subject to challenge by the Internal Revenue Service (the "IRS"). If the IRS challenges such a position and is successful, there may be substantial retroactive taxes, plus interest and possibly penalti

cording of 1-12 CONFIDENTIAL UBSTERRAMAR00003943 EFTA00239275 FOR EXISTING INVESTOR USE ONLY Taxation: ERISA and Other Tax Exempt Entities: Anti-Money Laundering Considerations: DOC ID- 29147063.5 transactions and the reconciliation of cash, positions and transactions between Millennium USA's and the Maste

of the Administrator's affiliates or employees for tax advice in connection with its investment. To ensure compliance with requirements imposed by the Internal Revenue Service (the "IRS") in Circular 230, you are hereby informed that any tax advice contained in this Memorandum (i) is written in connection with the promoti

lations promulgated thereunder) to equal or exceed 25% of the net asset value of any class of the Offered Interests. (See "ERISA Considerations.") Anti-Money Laundering As part of Millennium USA's and the Administrator's Considerations: responsibility for the prevention of money laundering, Millennium USA and its

of the Administrator's affiliates or employees for tax advice in connection with its investment. To ensure compliance with requirements imposed by the Internal Revenue Service (the "IRS") in Circular 230, you are hereby informed that any tax advice contained in this Memorandum (i) is written in connection with the promoti

lations promulgated thereunder) to equal or exceed 25% of the net asset value of any class of the Offered Interests. (See "ERISA Considerations.") Anti-Money Laundering As part of Millennium USA's and the Administrator's Considerations: responsibility for the prevention of money laundering, Millennium USA and its