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ted as a corporation for U.S. federal income tax purposes, created or organized under the laws of the United States or any state thereof, including the District of Columbia, (3) an estate the income of which is subject to U.S. federal income taxation regardless of its source or (4) a trust which (a) is subject to the p
all years of the Underlying Fund and the Underlying Master Fund unless revoked with the consent of the IRS. As a result of the Underlying Fund's and the Underlying Master Fund's mark-to-market election, the AlphaKeys Fund will generally be required to recognize ordinary gain or loss on all of the securities held by the Unde
2 mentions1 same-page
Page ?Same page
ted as a corporation for U.S. federal income tax purposes, created or organized under the laws of the United States or any state thereof, including the District of Columbia, (3) an estate the income of which is subject to U.S. federal income taxation regardless of its source or (4) a trust which (a) is subject to the p
ing obligations in non-U.S. jurisdictions, including withholding taxes on dividends, interest and proceeds. In particular, the Underlying Fund's and the Underlying Master Fund's non- U.S. investments may cause some of the income or gains of the AlphaKeys Fund to be subject to withholding or other taxes of non-U.S. jurisdicti
2 mentions1 same-page
Page ?Same page
ted as a corporation for U.S. federal income tax purposes, created or organized under the laws of the United States or any state thereof, including the District of Columbia, (3) an estate the income of which is subject to U.S. federal income taxation regardless of its source or (4) a trust which (a) is subject to the p
ing obligations in non-U.S. jurisdictions, including withholding taxes on dividends, interest and proceeds. In particular, the Underlying Fund's and the Underlying Master Fund's non- U.S. investments may cause some of the income or gains of the AlphaKeys Fund to be subject to withholding or other taxes of non-U.S. jurisdicti
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Mutual Connections (117)
Entities connected to both the District of Columbia and the Underlying Master Fund's
United States
LOCATION162 w/ the·3 w/ the
Ghislaine Maxwell
PERSON61 w/ the·2 w/ the
New York
LOCATION52 w/ the·3 w/ the
Philadelphia
LOCATION33 w/ the·2 w/ the
the Internal Revenue Service
ORGANIZATION30 w/ the·3 w/ the
U.S. Treasury
ORGANIZATION29 w/ the·3 w/ the
Federal Reserve
ORGANIZATION20 w/ the·2 w/ the
Cayman
LOCATION16 w/ the·3 w/ the
Keogh
ORGANIZATION15 w/ the·2 w/ the
Cayman Islands
LOCATION14 w/ the·2 w/ the
Paul Volcker
PERSON11 w/ the·3 w/ the
the U.S. Investment Company Act
ORGANIZATION11 w/ the·3 w/ the
FDIC
ORGANIZATION9 w/ the·2 w/ the
Anti-Money Laundering
ORGANIZATION8 w/ the·3 w/ the
the Federal Reserve System
ORGANIZATION7 w/ the·3 w/ the
the U.S. Department of Labor
ORGANIZATION6 w/ the·2 w/ the
Schulte Roth & Zabel LLP
ORGANIZATION5 w/ the·3 w/ the
the New York Stock Exchange
ORGANIZATION5 w/ the·2 w/ the
UBS AG
ORGANIZATION4 w/ the·3 w/ the
Non-U.S. Investments
ORGANIZATION4 w/ the·3 w/ the