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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
all years of the Underlying Fund and the Underlying Master Fund unless revoked with the consent of the IRS. As a result of the Underlying Fund's and the Underlying Master Fund's mark-to-market election, the AlphaKeys Fund will generally be required to recognize ordinary gain or loss on all of the securities held by the Unde
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
ing obligations in non-U.S. jurisdictions, including withholding taxes on dividends, interest and proceeds. In particular, the Underlying Fund's and the Underlying Master Fund's non- U.S. investments may cause some of the income or gains of the AlphaKeys Fund to be subject to withholding or other taxes of non-U.S. jurisdicti
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
ing obligations in non-U.S. jurisdictions, including withholding taxes on dividends, interest and proceeds. In particular, the Underlying Fund's and the Underlying Master Fund's non- U.S. investments may cause some of the income or gains of the AlphaKeys Fund to be subject to withholding or other taxes of non-U.S. jurisdicti
Entities connected to both the Internal Revenue Service and the Underlying Master Fund's

Ghislaine Maxwell
PERSON
FDIC
ORGANIZATION
Federal Reserve
ORGANIZATION
United States
LOCATION
New York
LOCATION
U.S. Treasury
ORGANIZATIONthe District of Columbia
LOCATION
Philadelphia
LOCATIONthe U.S. Investment Company Act
ORGANIZATION
Cayman Islands
LOCATIONCayman
LOCATIONKeogh
ORGANIZATIONthe Federal Reserve System
ORGANIZATION
UBS AG
ORGANIZATIONthe New York Stock Exchange
ORGANIZATION
Millennium
ORGANIZATIONTrigger Event
ORGANIZATIONMillennium USA's
LOCATIONErnst & Young LLP
ORGANIZATIONMillennium International, Ltd.
ORGANIZATION