3
Shared Docs
3
Same-Page
3 / 3
Mentions
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
el has been retained to represent Investors of the AlphaKeys Fund and the terms of this offering have not been negotiated on an arm's length basis. Ropes & Gray LLP's representation of the AlphaKeys Fund, the Administrator and their affiliates is limited to those specific matters upon which it has been consulted.
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
el has been retained to represent Investors of the AlphaKeys Fund and the terms of this offering have not been negotiated on an arm's length basis. Ropes & Gray LLP's representation of the AlphaKeys Fund, the Administrator and their affiliates is limited to those specific matters upon which it has been consulted.
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
el has been retained to represent Investors of the AlphaKeys Fund and the terms of this offering have not been negotiated on an arm's length basis. Ropes & Gray LLP's representation of the AlphaKeys Fund, the Administrator and their affiliates is limited to those specific matters upon which it has been consulted.
Entities connected to both Schulte Roth & Zabel LLP and Ropes & Gray LLP's

United States
LOCATION
New York
LOCATION
U.S. Treasury
ORGANIZATIONKeogh
ORGANIZATIONthe District of Columbia
LOCATIONCayman
LOCATION
Paul Volcker
PERSON
the Internal Revenue Service
ORGANIZATIONThe Master Partnership's Organization
ORGANIZATIONMillennium Partners
ORGANIZATIONMillennium USA's
LOCATIONMillennium International, Ltd.
ORGANIZATIONErnst & Young LLP
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONThis Confidential Memorandum
ORGANIZATIONTrigger Event
ORGANIZATIONOrganization, Management
ORGANIZATIONManagement of Millennium USA
ORGANIZATION
Millennium
ORGANIZATIONOrganization, Management, Structure
ORGANIZATION