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Document Mentions (3 shared documents)
2 mentions1 same-page
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e objective of the AlphaKeys Fund is to invest in the Underlying Fund. The Underlying Fund's principal trading objective (through its investment in Millennium Partners, L.P. (the "Underlying Muter Fund")) is to achieve above-average appreciation by opportunistically trading and investing in a wide variety of secu
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
2 mentions1 same-page
Page ?Same page
e objective of the AlphaKeys Fund is to invest in the Underlying Fund. The Underlying Fund's principal trading objective (through its investment in Millennium Partners, L.P. (the "Underlying Master Fund")) is to achieve above-average appreciation by opportunistically trading and investing in a wide variety of sec
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
2 mentions1 same-page
Page ?Same page
e objective of the AlphaKeys Fund is to invest in the Underlying Fund. The Underlying Fund's principal trading objective (through its investment in Millennium Partners, M. (the "Underlying Master Fund")) is to achieve above-average appreciation by opportunistically trading and investing in a wide variety of secur
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
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Mutual Connections (117)
Entities connected to both Millennium Partners and the Underlying Master Fund's
Millennium International, Ltd.
ORGANIZATION6 w/ Millennium·3 w/ the
New York
LOCATION6 w/ Millennium·3 w/ the
Cayman
LOCATION6 w/ Millennium·3 w/ the
The Master Partnership's Organization
ORGANIZATION6 w/ Millennium·3 w/ the
Management of Millennium USA
ORGANIZATION6 w/ Millennium·3 w/ the
Ernst & Young LLP
ORGANIZATION6 w/ Millennium·3 w/ the
the U.S. Investment Company Act
ORGANIZATION6 w/ Millennium·3 w/ the
Millennium USA's
LOCATION6 w/ Millennium·3 w/ the
U.S. Treasury
ORGANIZATION6 w/ Millennium·3 w/ the
Trigger Event
ORGANIZATION6 w/ Millennium·3 w/ the
Millennium
ORGANIZATION6 w/ Millennium·3 w/ the
United States
LOCATION5 w/ Millennium·3 w/ the
the Internal Revenue Service
ORGANIZATION5 w/ Millennium·3 w/ the
Millennium Offshore Intermediate
ORGANIZATION5 w/ Millennium·3 w/ the
Organization, Management, Structure
ORGANIZATION4 w/ Millennium·3 w/ the
Schulte Roth & Zabel LLP
ORGANIZATION4 w/ Millennium·3 w/ the
Capital Structure
ORGANIZATION5 w/ Millennium·2 w/ the
Master-Feeder Relationship
ORGANIZATION5 w/ Millennium·2 w/ the
Organization, Management
ORGANIZATION4 w/ Millennium·3 w/ the
Keogh
ORGANIZATION5 w/ Millennium·2 w/ the