Epstein Secrets

sion in effect for purposes of the New York City general corporation tax. Regulations under both the New York State corporate franchise tax and the New York City general corporation tax, however, provide an exception to this general rule in the case of a "portfolio investment partnership," which is defined, g

o report on its own annual tax return such Limited Partner's distributive share of the Partnership's taxable income or loss. (See "Tax Aspects.") Schulte Roth & Zabel LLP, 919 Third Avenue, New York, New York 10022, acts as legal counsel to the Partnership in connection with the offering of the Interests and with re

r affiliates. In connection with the offering and ongoing advice to the Partnership, Schulte Roth & Zabel LLP does not represent Limited Partners. Schulte Roth & Zabel LLP will not be representing Limited Partners of the Partnership. No independent counsel has been retained to represent Limited Partners of the Partn

sitory, clearing agency or omnibus customer account of such custodian. The Custodian's principal business address is 240 Greenwich Street, New York, New York 10286. The AlphaKeys Fund has also entered into an Escrow Agreement with BNY Mellon Investment Servicing (US) Inc. -61- CONFIDENTIAL UBSTERRAMAR00

he Offering — Interests Offered." For purposes of this Confidential Memorandum, a business day is any day, Monday through Friday, on which banks in New York City are open for business. DOC ID- 29147063.5 1-2 CONFIDENTIAL UBSTERRAMAR00003933 EFTA00239265 FOR EXISTING INVESTOR USE ONLY Purchaser Qualific

rvices; and (v) year-end support services with respect to Millennium USA's audit and tax processes, as may be required. (See "The Administrator.") Schulte Roth & Zabel LLP has rendered an opinion that Millennium USA and the Master Partnership will each be classified as a partnership and not as an association taxable a

SA is a Delaware limited partnership formed in November 1997. Millennium USA's principal office is located at 666 Fifth Avenue, 8th Floor, New York, New York 10103-0899. Master-Feeder Relationship As discussed in Part Two of this Confidential Memorandum under "The Master Partnership's Organization — Org

uch trade or business as not being subject to the foregoing limitations on deductibility. However, there can be no assurance that New York State and New York City will not treat such expenses as investment expenses which are subject to such limitations. Further, these limitations may apply to certain expenses

perations Classification of Millennium USA and the Master Partnership. Each of Millennium USA and the Master Partnership has received an opinion of Schulte Roth & Zabel LLP, its counsel, that under the provisions of the Code and the Regulations, as in effect on the date of the opinion, as well as under the relevant aut

ife cannot agree upon the nature and extent of such training, such decision shall be referred to the head rabbi of either Temple Emanu-El, New York, New York, or Park Avenue Synagogue, New York, New York, and the decision of such rabbi shall be final and binding on both parties. 2. (a) Except as provid

8 Attn: Anita S. Rosenbloom, Esq. B. All notices to the Husband shall be sent to him as follows: 950 Fifth Avenue New York, New York 10021 and Schulte Roth & Zabel LLP 900 Third Avenue New York, New York 10022 Attn: William D. Zabel, Esq. 25. pisclosure of Assets. A. The parties confirm that (i) to the extent

n, Elizabeth c:a.; Subject: Re: Professional Children's School I'll let you know. Gary Stein Partner Schulte Roth & Zabel LLP 919 Third Avenue. New York NY 10022 On Feb 22, 2020, at 11:05 PM, ca wrote: -CAUTION: EXTERNAL EMAIL Gary, I got your voicemail the other day, thank you — thanks for check

dren's School >; (USANYS) < Thanks= I too am pretty wide open tomorrow afternoon. Want to say 2 pm? Gary Stein Partner my pronouns: he/him/his Schulte Roth & Zabel LLP www.Srz.COM From: Sent: Wednesday, April 7, 2021 1:33 PM To: Stein, Gary Cc: Subject: Re: Professional Children's School Not a problem— what t

[email protected]>: ) Subject: Re: Professional Children's School I'll let you know. Gary Stein Partner Schulte Roth & Zabel LLP 919 Third Avenue New York NY 10022 fax On Feb 22, 2020, at 11:05 PM, c > wrote: -CAUTION: EXTERNAL EMAIL Gary, I got your voicemail the other day, thank you —thanks for c

y" < To: Cc: "I Subject: Re: Professional Children's School Date: Tue, 06 Apr 2021 21:41:15 +0000 (USANYS)" That's good. Gary Stein Partner Schulte Roth & Zabel LLP 919 Third Avenue. New York NY 10022 ax On Apr 6, 2021, at 5:01 PM, wrote: Thanks very much. Let's plan for 9:30 on Thursday morning, if that wor

eds an applicable threshold amount. Failure to comply with the reporting requirements gives rise to substantial penalties. Certain states, including New York, may also have similar disclosure requirements. Investors should consult their tax advisors to determine whether filing Form 8886 in accordance with

Administrator also provides services in connection with the issuance, transfer and withdrawal of interests. (See "The Administrator.") Taxation: Schulte Roth & Zabel LLP has rendered an opinion that Millennium USA and the Master Partnership will each be classified as a partnership and not as an association taxable a

eds an applicable threshold amount. Failure to comply with the reporting requirements gives rise to substantial penalties. Certain states, including New York, may also have similar disclosure requirements. Investors should consult their tax advisors to determine whether filing Form 8886 in accordance with

Administrator also provides services in connection with the issuance, transfer and withdrawal of interests. (See "The Administrator.") Taxation: Schulte Roth & Zabel LLP has rendered an opinion that Millennium USA and the Master Partnership will each be classified as a partnership and not as an association taxable a