3
Shared Docs
3
Same-Page
3 / 3
Mentions
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
of interests (e.g., currency hedges). As an investor in the Underlying Fund, the AlphaKeys Fund may be subject to these same risks with respect to the Underlying Fund Interests. Similarly, although Investors may hold separate classes, sub-classes or series of Interests, the AlphaKeys Fund is a single legal entity and its c
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
ies of shares (e.g., currency hedges). As an investor in the Underlying Fund, the AlphaKeys Fund may be subject to these same risks with respect to the Underlying Fund Interests. Idle Funds. The AlphaKeys Fund may retain a portion of the subscription proceeds that will not be invested in the Underlying Fund, to meet certain
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
ies of shares (e.g., currency hedges). As an investor in the Underlying Fund, the AlphaKeys Fund may be subject to these same risks with respect to the Underlying Fund Interests. Idle Funds. The AlphaKeys Fund may retain a portion of the subscription proceeds that will not be invested in the Underlying Fund, to meet certain
Entities connected to both the Underlying Master Fund's and the Underlying Fund Interests
the "UBS Americas"
ORGANIZATIONOrganization, Management, Structure
ORGANIZATIONInterests of the AlphaKeys Fund
ORGANIZATIONthe Underlying Fund Manager's
ORGANIZATIONTreatment as Partnership
ORGANIZATIONImportance of Obtaining Professional Advice
ORGANIZATIONthe UBSFS Advisory Program
ORGANIZATIONTHE ALPHAKEYS FUND IN LIGHT
ORGANIZATIONIndependent Auditors and Legal Counsel
ORGANIZATIONRopes & Gray LLP's
ORGANIZATIONNO OFFERING LITERATURE OR ADVERTISING
ORGANIZATIONManagement of Millennium USA
ORGANIZATIONThe Master Partnership's Organization
ORGANIZATIONOrganization, Management, Structure and Operations
ORGANIZATIONOrganization, Management
ORGANIZATIONMillennium Offshore Intermediate
ORGANIZATIONthe "Intermediate Partnership
ORGANIZATIONDifferent Returns Among Investors
ORGANIZATIONthe Master Partnership or Portfolio Managers
ORGANIZATIONIsrael A. Englander
PERSON