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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
ts investments from outside investors and primarily invests its capital in the Master Partnership (or its underlying strategies) indirectly through Millennium Offshore Intermediate, L.P., a Cayman Islands exempted limited partnership (the "Intermediate Partnership"), which, in turn, invests all or substantially all of its capi
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
hip"). Millennium International, Ltd. ("Millennium International"), accepts investments from outside investors and primarily invests its capital in Millennium Offshore Intermediate, L.P., a Cayman Islands exempted limited partnership (the "Intermediate Partnership"), which, in turn, invests all or substantially all of its capi
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
hip"). Millennium International, Ltd. ("Millennium International"), accepts investments from outside investors and primarily invests its capital in Millennium Offshore Intermediate, •., a Cayman Islands exempted limited partnership (the "Intermediate Partnership"), which, in turn, invests all or substantially all of its capita
Entities connected to both the Underlying Master Fund's and Millennium Offshore Intermediate
The Master Partnership's Organization
ORGANIZATION
New York
LOCATION
United States
LOCATIONMillennium International, Ltd.
ORGANIZATIONTrigger Event
ORGANIZATIONErnst & Young LLP
ORGANIZATIONCayman
LOCATIONMillennium Partners
ORGANIZATIONthe U.S. Investment Company Act
ORGANIZATION
Millennium
ORGANIZATIONManagement of Millennium USA
ORGANIZATIONMillennium USA's
LOCATION
U.S. Treasury
ORGANIZATION
the Internal Revenue Service
ORGANIZATIONKeogh
ORGANIZATION
Paul Volcker
PERSONCustodian
ORGANIZATION
UBS AG
ORGANIZATIONthe Federal Reserve System
ORGANIZATIONNon-U.S. Investments
ORGANIZATION