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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
nd Expenses" in Part Two of the Underlying Fund Memorandum for further discussion of the Underlying Fund's and Underlying Master Fund's expenses. BNY Mellon Alternative Investment Services (the "Sub- Administrator") performs certain administration, accounting and investor services for the AlphaKeys Fund and other investment funds spon
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
Part Two of the Underlying Fund Memorandum for further discussion of the Underlying Fund's and Underlying Master Fund's expenses. OTHER EXPENSES BNY Mellon Alternative Investment Services (the "Sub-. Administrator") performs certain administration, accounting and investor services for the AlphaKeys Fund and other investment funds sp
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
the Underlying Fund Memorandum for further discussion of the Underlying Fund's and Underlying Master Fund's expenses. OTHER EXPENSES MEVIAXWELL BNY Mellon Alternative Investment Services (the "Sub-. Administrator") performs certain administration, accounting and investor services for the AlphaKeys Fund and other investment funds sp
Entities connected to both Schulte Roth & Zabel LLP and BNY Mellon Alternative Investment Services

United States
LOCATION
New York
LOCATION
Millennium
ORGANIZATION
U.S. Treasury
ORGANIZATIONthe District of Columbia
LOCATION
Paul Volcker
PERSONKeogh
ORGANIZATIONCayman
LOCATION
the Internal Revenue Service
ORGANIZATION
Ghislaine Maxwell
PERSONMillennium Partners
ORGANIZATIONErnst & Young LLP
ORGANIZATIONMillennium USA's
LOCATIONOrganization, Management, Structure
ORGANIZATIONMillennium International, Ltd.
ORGANIZATIONMillennium USA LP
ORGANIZATIONTrigger Event
ORGANIZATIONThis Confidential Memorandum
ORGANIZATIONOrganization, Management
ORGANIZATIONManagement of Millennium USA
ORGANIZATION