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t is expected to develop in the future. Neither the General Partner nor the Investment Manager is authorized or expected to become authorized under the European Union's Directive 2011/61/EU on Alternative Investment Fund Managers (the "AIFM Directive") as of the date of this Memorandum, and the substantive requir
ome if they borrow funds, or (iii) generate some income, transaction fees, each of which may cause investors that are U.S. Tax amounts of UBTI. A U.S. TaxExempt Investor's allocable share of Access subject to federal income taxation and might U.S. Tax-Exempt Investors only invest in the Access amounts o
t is expected to develop in the future. Neither the General Partner nor the Investment Manager is authorized or expected to become authorized under the European Union's Directive 2011/61/EU on Alternative Investment Fund Managers (the "AIFM Directive") as of the date of this Memorandum, and the substantive requir
ome if they borrow funds, or (iii) generate some income, transaction fees, each of which may cause investors that are U.S. Tax amounts of UBTI. A U.S. TaxExempt Investor's allocable share of Access subject to federal income taxation and might U.S. Tax-Exempt Investors only invest in the Access amounts o
t is expected to develop in the future. Neither the General Partner nor the Investment Manager is authorized or expected to become authorized under the European Union's Directive 2011/61/EU on Alternative Investment Fund Managers (the "AIFM Directive") as of the date of this Memorandum, and the substantive requir
ome if they borrow funds, or (iii) generate some income, transaction fees, each of which may cause investors that are U.S. Tax amounts of UBTI. A U.S. TaxExempt Investor's allocable share of Access subject to federal income taxation and might U.S. Tax-Exempt Investors only invest in the Access amounts o
t is expected to develop in the future. Neither the General Partner nor the Investment Manager is authorized or expected to become authorized under the European Union's Directive 2011/61/EU on Alternative Investment Fund Managers (the "AIFM Directive") as of the date of this Memorandum, and the substantive requir
ome if they borrow funds, or (iii) generate some income, transaction fees, each of which may cause investors that are U.S. Tax amounts of UBTI. A U.S. TaxExempt Investor's allocable share of Access subject to federal income taxation and might U.S. Tax-Exempt Investors only invest in the Access amounts o
t is expected to develop in the future. Neither the General Partner nor the Investment Manager is authorized or expected to become authorized under the European Union's Directive 2011/61/EU on Alternative Investment Fund Managers (the "AIFM Directive") as of the date of this Memorandum, and the substantive requir
ome if they borrow funds, or (iii) generate some income, transaction fees, each of which may cause investors that are U.S. Tax amounts of UBTI. A U.S. TaxExempt Investor's allocable share of Access subject to federal income taxation and might U.S. Tax-Exempt Investors only invest in the Access amounts o
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