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artners, (ii) that is required or contemplated by this Agreement, or (iii) that is necessary or desirable to implement new regulations published by the Internal Revenue Service with respect to partnership allocations of income, gain, loss, deduction and credit; a change to cure any ambiguity, to correct or supplement any p
rent market value of all short sale obligations; (D) All accrued liabilities of the Partnership to the General Partner, the Investment Manager and the Portfolio Managers; and (E) All other liabilities and expenses, including such reserves as the General Partner may reasonably deem advisable for unknown or unfixed
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
284 FOR EXISTING INVESTOR USE ONLY fringe benefits, bonuses, fees and performance-based compensation (collectively "Compensation") paid to the Portfolio Managers and other employees of, and consultants to the Master Partnership and its affiliates. Compensation expenses will also generally include management
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
ro rata) portion of the expenses, salaries, fringe benefits, bonuses, fees and performance-based compensation (collectively "Compensation") paid to the Portfolio Managers and other employees of, and consultants to the Master Partnership and its affiliates. Compensation expenses may also include management or "base" f
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
ro rata) portion of the expenses, salaries, fringe benefits, bonuses, fees and performance-based compensation (collectively "Compensation") paid to the Portfolio Managers and other employees of, and consultants to the Master Partnership and its affiliates. Compensation expenses may also include management or "base" f
Entities connected to both the Internal Revenue Service and the Portfolio Managers

JPMorgan Chase
ORGANIZATION
Ghislaine Maxwell
PERSONthe State of New York
LOCATION
FDIC
ORGANIZATION
Federal Reserve
ORGANIZATION
United States
LOCATION
Department of Justice
ORGANIZATION
Samantha Power
PERSONthe Securities and Exchange Commission
ORGANIZATION
New York
LOCATION
U.S. Treasury
ORGANIZATION
Marc Rich
PERSONthe District of Columbia
LOCATION
Philadelphia
LOCATIONthe U.S. Investment Company Act
ORGANIZATION
New York State
LOCATIONCayman
LOCATION
Cayman Islands
LOCATION
UBS AG
ORGANIZATIONKeogh
ORGANIZATION