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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
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
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
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
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
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 Treatment as Partnership 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