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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
n Investor other than its investment in the AlphaKeys Fund may affect the tax consequences to such Investor of an investment in the AlphaKeys Fund. Treatment as Partnership. It is intended that the AlphaKeys Fund will be treated as a partnership for U.S. federal income tax purposes and not as an association or "publicly
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
nvestor other than its investment in the Alpha Keys Fund may affect the tax consequences to such Investor of an investment in the Alpha Keys Fund. Treatment as Partnership. It is intended that the Alpha Keys Fund will be treated as a partnership for U.S. federal income tax purposes and not as an association or "public
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
nvestor other than its investment in the Alpha Keys Fund may affect the tax consequences to such Investor of an investment in the Alpha Keys Fund. Treatment as Partnership. It is intended that the Alpha Keys Fund will be treated as a partnership for U.S. federal income tax purposes and not as an association or "public
Entities connected to both Millennium Partners and Treatment as Partnership
Millennium International, Ltd.
ORGANIZATION
New York
LOCATIONCayman
LOCATIONThe Master Partnership's Organization
ORGANIZATIONManagement of Millennium USA
ORGANIZATIONErnst & Young LLP
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATIONMillennium USA's
LOCATION
U.S. Treasury
ORGANIZATIONTrigger Event
ORGANIZATION
Millennium
ORGANIZATION
United States
LOCATION
the Internal Revenue Service
ORGANIZATIONMillennium Offshore Intermediate
ORGANIZATIONOrganization, Management, Structure
ORGANIZATIONSchulte Roth & Zabel LLP
ORGANIZATIONCapital Structure
ORGANIZATIONMaster-Feeder Relationship
ORGANIZATIONOrganization, Management
ORGANIZATIONKeogh
ORGANIZATION