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atters partner shall employ experienced tax counsel to represent the Partnership in connection with any audit or investigation of the Partnership by the Internal Revenue Service and in connection with all subsequent administrative and judicial proceedings arising out of such audit. If the tax matters partner is required by
of their respective unfunded Capital Commitments shall be increased accordingly. 3.3 Removal of the General Partner. (a) Immediately following a Trigger Event (as defined below), the General Partner shall provide notice to the Limited Partners of the Trigger Event, and at the election of Two-Thirds in Int
atters partner shall employ experienced tax counsel to represent the Partnership in connection with any audit or investigation of the Partnership by the Internal Revenue Service and in connection with all subsequent administrative and judicial proceedings arising out of such audit. If the tax matters partner is required by
of their respective unfunded Capital Commitments shall be increased accordingly. 3.3 Removal of the General Partner. (a) Immediately following a Trigger Event (as defined below), the General Partner shall provide notice to the Limited Partners of the Trigger Event, and at the election of Two-Thirds in Int
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
or be deemed to create, any special withdrawal right for the holders of the Offered Interests (in their capacity as such). Upon the occurrence of a Trigger Event, holders of the Offered Interests will be subject to Millennium Management's plan for the continuation of its operations. More broadly, whether in
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
occurring before the last day of the fourth full calendar quarter after purchase of such Offered Interests (other than due to the occurrence of a Trigger Event, described below) will be subject to a charge equal to 4% of the withdrawal amount (the "Early Withdrawal Charge"). For purposes of determining the
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
be deemed to be made on a first-in first-out basis absent specific instructions to the contrary from the investor. Special Withdrawal Right upon a Trigger Event. Millennium Management will notify the Limited Partners within 10 days of the occurrence of the death, disability, adjudication of incompetency, ba
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
occurring before the last day of the fourth full calendar quarter after purchase of such Offered Interests (other than due to the occurrence of a Trigger Event, described below) will be subject to a charge equal to 4% of the withdrawal amount (the "Early Withdrawal Charge"). For purposes of determining the
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
be deemed to be made on a first-in first-out basis absent specific instructions to the contrary from the investor. Special Withdrawal Right upon a Trigger Event. Millennium Management will notify the Limited Partners within 10 days of the occurrence of the death, disability, adjudication of incompetency, ba
Entities connected to both the Internal Revenue Service and Trigger Event

JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSONthe State of New York
LOCATION
FDIC
ORGANIZATION
Federal Reserve
ORGANIZATION
United States
LOCATION
George W. Bush
PERSON
Prince Andrew
PERSON
Samantha Power
PERSONthe Securities and Exchange Commission
ORGANIZATION
New York
LOCATION
Eric Holder
PERSON
U.S. Treasury
ORGANIZATIONthe District of Columbia
LOCATIONthe U.S. Investment Company Act
ORGANIZATION
Philadelphia
LOCATION
United Kingdom
LOCATION
Wilbur Ross
PERSON
New York State
LOCATIONCayman
LOCATION