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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
atters Relating to an Investment in Millennium USA" and "Certain Tax Matters Relating to the Master Partnership" in the Underlying Fund Memorandum. Importance of Obtaining Professional Advice The foregoing analysis is not intended as a substitute for careful tax planning. Accordingly, prospective Investors in the AlphaKeys Fund are stron
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
tters Relating to an Investment in Millennium USA" and "Certain Tax Matters Relating to the Master Partnership" in the Underlying Fund Memorandum. Importance of Obtaining Professional Advice The foregoing analysis is not intended as a substitute for careful tax planning. Accordingly, prospective Investors in the AlphaKeys Fund are stron
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
tters Relating to an Investment in Millennium USA" and "Certain Tax Matters Relating to the Master Partnership" in the Underlying Fund Memorandum. Importance of Obtaining Professional Advice The foregoing analysis is not intended as a substitute for careful tax planning. Accordingly, prospective Investors in the AlphaKeys Fund are stron
Entities connected to both the Internal Revenue Service and Importance of Obtaining Professional Advice

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