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Millennium Fund. This document is not intended or written to be used, and cannot be used, by any Investor for the purpose of avoiding penalties that the Internal Revenue Service might seek to impose on such Investor. Each Investor should seek advice based upon such Investor's circumstances from an independent tax adviser. L
LP (the "Millennium Master Fund") and the results presented through December 31, 1997 are those of the Millennium Master Fund. Millennium USA LP and Millennium International, Ltd., which commenced operations on January I, 1998, and Millennium Strategic Capital, which commenced operations on July 1, 2011, invest primarily in th
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
ip") and may also invest through separate legal entities directly in the Master Partnership's underlying strategies. In addition to Millennium USA, Millennium International, Ltd. ("Millennium International") also accepts investments from outside investors and primarily invests its capital in the Master Partnership (or its un
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
Millennium USA accepts investments from outside investors and primarily invests its capital in Millennium Partners, L.P. (the "Master Partnership"). Millennium International, Ltd. ("Millennium International"), accepts investments from outside investors and primarily invests its capital in Millennium Offshore Intermediate, L.P
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
ors" and "qualified purchasers" under the U.S. federal securities laws. Millennium USA primarily invests its capital in the Master Partnership. • Millennium International, Ltd. ("Millennium International"), an exempted company incorporated in December 1997 under the laws of the Cayman Islands, which accepts investments fro
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
." Millennium USA accepts investments from outside investors and primarily invests its capital in Millennium Partners, (the "Master Partnership"). Millennium International, Ltd. ("Millennium International"), accepts investments from outside investors and primarily invests its capital in Millennium Offshore Intermediate, •.,
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
ors" and "qualified purchasers" under the U.S. federal securities laws. Millennium USA primarily invests its capital in the Master Partnership. • Millennium International, Ltd. ("Millennium International"), an exempted company incorporated in December 1997 under the laws of the Cayman Islands, which accepts investments fro
Entities connected to both the Internal Revenue Service and Millennium International, Ltd.

JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSONthe State of New York
LOCATION
FDIC
ORGANIZATION
Federal Reserve
ORGANIZATION
United States
LOCATION
George W. Bush
PERSON
Julie K. Brown
PERSON
New York
LOCATIONthe Securities and Exchange Commission
ORGANIZATION
U.S. Treasury
ORGANIZATIONthe District of Columbia
LOCATIONthe U.S. Investment Company Act
ORGANIZATION
Philadelphia
LOCATION
Wilbur Ross
PERSON
United Kingdom
LOCATION
New York State
LOCATIONCayman
LOCATION
Cayman Islands
LOCATIONKeogh
ORGANIZATION