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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
atters Relating to an Investment in Millennium USA" and "Certain Tax Matters Relating to the Master Partnership" in the Underlying Fund Memorandum. Importance of Obtaining Professional Advice The foregoing analysis is not intended as a substitute for careful tax planning. Accordingly, prospective Investors in the AlphaKeys Fund are stron
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
tters Relating to an Investment in Millennium USA" and "Certain Tax Matters Relating to the Master Partnership" in the Underlying Fund Memorandum. Importance of Obtaining Professional Advice The foregoing analysis is not intended as a substitute for careful tax planning. Accordingly, prospective Investors in the AlphaKeys Fund are stron
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
tters Relating to an Investment in Millennium USA" and "Certain Tax Matters Relating to the Master Partnership" in the Underlying Fund Memorandum. Importance of Obtaining Professional Advice The foregoing analysis is not intended as a substitute for careful tax planning. Accordingly, prospective Investors in the AlphaKeys Fund are stron
Entities connected to both the Underlying Master Fund's and Importance of Obtaining Professional Advice
the "UBS Americas"
ORGANIZATIONOrganization, Management, Structure
ORGANIZATIONInterests of the AlphaKeys Fund
ORGANIZATIONthe Underlying Fund Interests
ORGANIZATIONthe Underlying Fund Manager's
ORGANIZATIONTreatment as Partnership
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