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ip") and may also invest through separate legal entities directly in the Master Partnership's underlying strategies. In addition to Millennium USA, Millennium International, Ltd. ("Millennium International") also accepts investments from outside investors and primarily invests its capital in the Master Partnership (or its un
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
Millennium USA accepts investments from outside investors and primarily invests its capital in Millennium Partners, L.P. (the "Master Partnership"). Millennium International, Ltd. ("Millennium International"), accepts investments from outside investors and primarily invests its capital in Millennium Offshore Intermediate, L.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
." Millennium USA accepts investments from outside investors and primarily invests its capital in Millennium Partners, (the "Master Partnership"). Millennium International, Ltd. ("Millennium International"), accepts investments from outside investors and primarily invests its capital in Millennium Offshore Intermediate, •.,
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
Entities connected to both Millennium International, Ltd. and the Underlying Master Fund's

Millennium
ORGANIZATIONMillennium USA's
LOCATION
U.S. Treasury
ORGANIZATIONThe Master Partnership's Organization
ORGANIZATIONManagement of Millennium USA
ORGANIZATIONErnst & Young LLP
ORGANIZATIONMillennium Partners
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
United States
LOCATIONCayman
LOCATIONTrigger Event
ORGANIZATION
the Internal Revenue Service
ORGANIZATION
New York
LOCATIONMillennium Offshore Intermediate
ORGANIZATIONSchulte Roth & Zabel LLP
ORGANIZATION
Ghislaine Maxwell
PERSONCapital Structure
ORGANIZATIONOrganization, Management
ORGANIZATIONMaster-Feeder Relationship
ORGANIZATIONGlobeOp Financial Services
ORGANIZATION