5
Total Mentions
5
Documents
120
Connected Entities
Organization referenced in documents
EFTA00292433
und, either directly or through flow through entities treated as transparent for U.S. federal income tax purposes, lack economic substance. Certain Non-U.S. Investments. Pursuant to various "anti-deferral" provisions of the Code (the "Subpart F" and PFIC provisions), any investments by the Fund in certain foreign co
EFTA00239188_sub_001 - EFTA00239188_100
is urged to consult with its own tax advisor regarding the U.S. and non-U.S. tax treatment of an investment in the AlphaKeys Fund. Implications of Non-U.S. Investments Certain non-U.S. investments of the Underlying Fund and the Underlying Master Fund, including investments in "controlled foreign corporations" and
EFTA00237816_sub_001 - EFTA00237816_100
is urged to consult with its own tax advisor regarding the U.S. and non-U.S. tax treatment of an investment in the AlphaKeys Fund. Implications of Non-U.S. Investments Certain non-U.S. investments of the Underlying Fund and the Underlying Master Fund, including investments in "controlled foreign corporations" and
EFTA00236853_sub_001 - EFTA00236853_100
is urged to consult with its own tax advisor regarding the U.S. and non-U.S. tax treatment of an investment in the AlphaKeys Fund. Implications of Non-U.S. Investments Certain non-U.S. investments of the Underlying Fund and the Underlying Master Fund, including investments in "controlled foreign corporations" and
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ut regard to the length of time held. Any active short-term trading of the Fund will increase its rate of turnover and related transaction expenses. Non-U.S. Investments The Fund may invest a portion of Fund’s total committed capital in the securities of issuers that are organized outside of the U.S. and Canada. Inve

United States
LocationCountry located primarily in North America
Cayman
LocationBritish Overseas Territory in the Caribbean
the District of Columbia
LocationFederal district, capital of the United States

the Internal Revenue Service
OrganizationInternal Revenue Service (IRS), US government agency responsible for tax collection and enforcement
the Underlying Fund Manager's
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Treatment as Partnership
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Importance of Obtaining Professional Advice
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the UBSFS Advisory Program
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THE ALPHAKEYS FUND IN LIGHT
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Independent Auditors and Legal Counsel
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Ropes & Gray LLP's
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NO OFFERING LITERATURE OR ADVERTISING
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Management of Millennium USA
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The Master Partnership's Organization
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Organization, Management, Structure and Operations
OrganizationOrganization referenced in documents
Organization, Management
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Millennium Offshore Intermediate
OrganizationOrganization referenced in documents
the "Intermediate Partnership
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Different Returns Among Investors
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the Master Partnership or Portfolio Managers
OrganizationOrganization referenced in documents