3
Shared Docs
3
Same-Page
3 / 3
Mentions
in Millennium USA does not constitute a complete investment program and (iii) that fully understand and are willing to assume the risks involved in Millennium USA's investment program. Millennium USA's investment practices, by their nature, may be considered to involve a substantial degree of risk. (See "Certai
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
n Millennium USA does not constitute a complete investment program, and (iii) that fully understand and are willing to assume the risks involved in Millennium USA's investment program. Millennium USA's investment practices, by their nature, may be considered to involve a substantial degree of risk. (See "Certa
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
n Millennium USA does not constitute a complete investment program, and (iii) that fully understand and are willing to assume the risks involved in Millennium USA's investment program. Millennium USA's investment practices, by their nature, may be considered to involve a substantial degree of risk. (See "Certa
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 USA's and the Underlying Master Fund's

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