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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
sets of the AlphaKeys Fund from being considered "plan assets" within the meaning of the Plan Assets Rules by limiting investment in each class of Interests of the AlphaKeys Fund by "Benefit Plan Investors" (as defined in the Plan Assets Rules and described in CERTAIN ERISA AND OTHER CONSIDERATIONS below) to a level that wo
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
sets of the Alpha Keys Fund from being considered "plan assets" within the meaning of the Plan Assets Rules by limiting investment in each class of Interests of the AlphaKeys Fund by "Benefit Plan Investors" (as defined in the Plan Assets Rules and described in CERTAIN ERISA AND OTHER CONSIDERATIONS below) to a level t
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
sets of the Alpha Keys Fund from being considered "plan assets" within the meaning of the Plan Assets Rules by limiting investment in each class of Interests of the AlphaKeys Fund by "Benefit Plan Investors" (as defined in the Plan Assets Rules and described in CERTAIN ERISA AND OTHER CONSIDERATIONS below) to a level t
Entities connected to both the Internal Revenue Service and Interests of the AlphaKeys Fund

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