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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
n Investor other than its investment in the AlphaKeys Fund may affect the tax consequences to such Investor of an investment in the AlphaKeys Fund. Treatment as Partnership. It is intended that the AlphaKeys Fund will be treated as a partnership for U.S. federal income tax purposes and not as an association or "publicly
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
nvestor other than its investment in the Alpha Keys Fund may affect the tax consequences to such Investor of an investment in the Alpha Keys Fund. Treatment as Partnership. It is intended that the Alpha Keys Fund will be treated as a partnership for U.S. federal income tax purposes and not as an association or "public
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
nvestor other than its investment in the Alpha Keys Fund may affect the tax consequences to such Investor of an investment in the Alpha Keys Fund. Treatment as Partnership. It is intended that the Alpha Keys Fund will be treated as a partnership for U.S. federal income tax purposes and not as an association or "public
Entities connected to both the Internal Revenue Service and Treatment as Partnership

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