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in the event Class B Interests are offered to a non-U.S. Investor, the AlphaKeys Fund may provide such Investor additional information. Prospective non-U.S. Investors should inform themselves as to the legal requirements and tax consequences within the countries of their citizenship, residence, domicile and place
nvestor (the "Investor Application"). -42- CONFIDENTIAL UBSTERRAMAR00003904 EFTA00239236 FOR EXISTING INVESTOR USE ONLY VL TAX ASPECTS Certain Material United States Federal Income Tax Considerations The following is a general summary of certain U.S. federal income tax considerations relating to an investment in
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estors; in the event Interests are offered to a non-U.S. Investor, the AlphaKeys Fund may provide such Investor additional information. Prospective non-U.S. Investors should inform themselves as to the legal requirements and tax consequences within the countries of their citizenship, residence, domicile and place
prospective Investor (the "Investor Application"). ML281817-MAXWELL -39- CONFIDENTIAL UBSTERRAMAR00002305 EFTA00237861 VI. TAX ASPECTS Certain Material United States Federal Income Tax Considerations To ensure compliance with requirements imposed by the IRS in Circular 230, you are hereby informed that any tax a
2 mentions1 same-page
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estors; in the event Interests are offered to a non-U.S. Investor, the AlphaKeys Fund may provide such Investor additional information. Prospective non-U.S. Investors should inform themselves as to the legal requirements and tax consequences within the countries of their citizenship, residence, domicile and place
by each prospective Investor (the "Investor Application"). MAXWELL -39- CONFIDENTIAL UBSTERRAMAR00001252 EFTA00236898 VI. TAX ASPECTS Certain Material United States Federal Income Tax Considerations To ensure compliance with requirements imposed by the IRS in Circular 230, you are hereby informed that any tax a
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United States
LOCATION20 w/ non-U.S.·4 w/ Material
the U.S. Investment Company Act
ORGANIZATION8 w/ non-U.S.·3 w/ Material
the District of Columbia
LOCATION4 w/ non-U.S.·3 w/ Material
Treatment as Partnership
ORGANIZATION3 w/ non-U.S.·3 w/ Material
Importance of Obtaining Professional Advice
ORGANIZATION3 w/ non-U.S.·3 w/ Material
the UBSFS Advisory Program
ORGANIZATION3 w/ non-U.S.·3 w/ Material
THE ALPHAKEYS FUND IN LIGHT
ORGANIZATION3 w/ non-U.S.·3 w/ Material
Independent Auditors and Legal Counsel
ORGANIZATION3 w/ non-U.S.·3 w/ Material
Ropes & Gray LLP's
ORGANIZATION3 w/ non-U.S.·3 w/ Material
NO OFFERING LITERATURE OR ADVERTISING
ORGANIZATION3 w/ non-U.S.·3 w/ Material
Management of Millennium USA
ORGANIZATION3 w/ non-U.S.·3 w/ Material
The Master Partnership's Organization
ORGANIZATION3 w/ non-U.S.·3 w/ Material
Organization, Management, Structure and Operations
ORGANIZATION3 w/ non-U.S.·3 w/ Material
Organization, Management
ORGANIZATION3 w/ non-U.S.·3 w/ Material
Millennium Offshore Intermediate
ORGANIZATION3 w/ non-U.S.·3 w/ Material
the "Intermediate Partnership
ORGANIZATION3 w/ non-U.S.·3 w/ Material
Different Returns Among Investors
ORGANIZATION3 w/ non-U.S.·3 w/ Material
the Master Partnership or Portfolio Managers
ORGANIZATION3 w/ non-U.S.·3 w/ Material
IE
Israel A. Englander
PERSON3 w/ non-U.S.·3 w/ Material
Ernst & Young LLP
ORGANIZATION3 w/ non-U.S.·3 w/ Material