Epstein Secrets

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

proceeds) made with respect to certain actual and deemed U.S. investments, the Master Partnership has registered with the Internal Revenue Service (the "Service") and generally will be required to identify, and report information with respect to, certain direct and indirect U.S. account holders (including d

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

ium USA and its Partners which should be considered by a Limited Partner. Millennium USA has not sought a ruling from the Internal Revenue Service (the "Service") or any other federal, state or local agency with respect to any of the tax issues affecting Millennium USA, nor has it obtained an opinion of cou

p," which is defined, generally, as a partnership which meets the gross income requirements of Section 851(bX2) of the Code. New York State (but not New York City) has adopted regulations that also include income and gains from commodity transactions described in Section 864(b)(2)(BXiii) as qualifying gross in

es in such circumstances. Millennium USA's Independent Public Accountants Millennium USA has retained Ernst & Young LLP, 5 Times Square, New York, New York 10036, certified public accountants, as its auditor. ML281817-MAXWELL I40 CONFIDENTIAL UBSTERRAMAR00002410 EFTA00237966 APPENDIX I TO PART ONE

ium USA and its Partners which should be considered by a Limited Partner. Millennium USA has not sought a ruling from the Internal Revenue Service (the "Service") or any other federal, state or local agency with respect to any of the tax issues affecting Millennium USA, nor has it obtained an opinion of cou

p," which is defined, generally, as a partnership which meets the gross income requirements of Section 851(bX2) of the Code. New York State (but not New York City) has adopted regulations that also include income and gains from commodity transactions described in Section 864(b)(2)(BXiii) as qualifying gross in

es in such circumstances. Millennium USA's Independent Public Accountants Millennium USA has retained Ernst & Young LLP, 5 Times Square, New York, New York 10036, certified public accountants, as its auditor. -MAXWELL I-80 CONFIDENTIAL UBSTERRAMAR00001357 EFTA00237003 APPENDIX I TO PART ONE: DESCR

ium USA and its Partners which should be considered by a Limited Partner. Millennium USA has not sought a ruling from the Internal Revenue Service (the "Service") or any other federal, state or local agency with respect to any of the tax issues affecting Millennium USA, nor has it obtained an opinion of cou

esponsibletles that you do not understand, you should seek legal advice. Liability of Agent: The meaning of the authority given to you Is defined in New York's General Obligations Law, Ankle 5, Title 15. If It is found that you have violated the law or acted outside the authority granted to you in the Power

Balances of both Income and Principal Balances of Income only To Bank Name: Account Name: ABA It or ACH Account N. VII. ACCESS TO DB INSIGHT (the "Service") (choose one) !DB InSight Standard includes access to financial and account information, research and product information. Paper statements and

sponsibilities that you do not understand, you should seek legal advice. liability of Agent: The meaning of the authority given to you Is defined In New York's General Obligations Law, Article 5. Title 15. If it is found that you have violated the law or acted outside the authority granted to you In the Pow

h Income and Principal Balances of Income only 0 To: Bank Name: O Account Name: Z ABA 0 or ACH 11 Account it 0 VII. ACCESS TO DB INSIGHT (the "Service") (choose one) Z DB Insight Standard includes access to financial and account information, research and product information. Paper statements and

esponsibilities that you do not understand. you should seek legal advice. LiabIllty of Agent: The meaning of the authority given to you Is dented In New York's General Obligations Law, Ankle 5, Tile 15. If it Is found that you have violated the law or acted outside the authority granted to you in the Power

Balances of both Income and Principal Balances of Income only To Bank Name: Account Name: ABA 8 or ACM IL Account • VII. ACCESS TO DB INSIGHT (the "Service") (choose one) DB InSight Standard includes access to financial and account information, research and product information. Paper 1 statements and

esponsitikties that you do not understand, you should seek legal advice. Liability of Agent: The meaning of the authority given to you Is defined In New York's General Obligations Law, Artkle 5, Tide 15. If it is found that you have violated the law or acted outside the authority granted to you in the Power

Balances of both Income and Principal Balances of Income only To: Bank Name: Account Name: ABA If or ACH Account I: VII. ACCESS TO DB INSIGHT (the "Service") (choose one) /DB Insight Standard includes access to financial and account information, research and product information. Paper statements and c

es not tax individuals who are not residents of New York City. A Partner which is a non-New York corporation may not be subject to New York State or New York City tax solely as a result of being a Partner in the Partnership because of an exception for limited partners in portfolio investment partnerships, whic

ied as an association taxable as a corporation (as a result of changed interpretations or administrative positions by the Internal Revenue Service (the "Service") or otherwise), the taxable income of the Partnership would be subject to corporate income taxation when recognized by the Partnership, and distri

ship is December 31. The Master Partnership's Independent Public Accountants The Master Partnership has retained Ernst & Young LLP, 5 Times Square, New York, New York 10036, certified public accountants, as its auditor. 11-82 CONFIDENTIAL UBSTERRAMAR00004085 EFTA00239417 FOR EXISTING INVESTOR USE ON

eds) made with respect to certain actual and deemed U.S. investments, the Master Partnership has registered with the U.S. Internal Revenue Service (the "Service") and generally will be required to identify, and report information with respect to, certain direct and indirect U.S. account holders (including de