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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
nd invests (even if, with respect to such partnership, the Underlying Fund was not a partner of the partnership during the tax year under audit). United States Tax Reporting by Limited Partners that are Owners of Non-U.S. Entities. United States tax rules impose information reporting requirements on U.S. persons that own, either directly
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
nd invests (even if, with respect to such partnership, the Underlying Fund was not a partner of the partnership during the tax year under audit). United States Tax Reporting by Limited Partners that are Owners of Non-U.S. Entities. United States tax rules impose information reporting requirements on U.S. persons that own, either directly
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
nd invests (even if, with respect to such partnership, the Underlying Fund was not a partner of the partnership during the tax year under audit). United States Tax Reporting by Limited Partners that are Owners of Non-U.S. Entities. United States tax rules impose information reporting requirements on U.S. persons that own, either directly
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
nd invests (even if, with respect to such partnership, the Underlying Fund was not a partner of the partnership during the tax year under audit). United States Tax Reporting by Limited Partners that are Owners of Non-U.S. Entities. United States tax rules impose information reporting requirements on U.S. persons that own, either directly
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
nd invests (even if, with respect to such partnership, the Underlying Fund was not a partner of the partnership during the tax year under audit). United States Tax Reporting by Limited Partners that are Owners of Non-U.S. Entities. United States tax rules impose information reporting requirements on U.S. persons that own, either directly
Entities connected to both European Union and United States Tax Reporting by Limited Partners

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