r accumulated earnings and profits of the Partnership; and Partners would not be entitled to report profits or losses realized by the Partnership. The Master Fund operates as a pass-through entity for Federal tax purposes and not as an entity taxable as a corporation. The HB Fund will be treated as a disregard

AGP LP 519 Alpha Group Capital Paul Barrett Cayman Islands Taxation The Master Fund has been advised by its Cayman Islands counsel, Ogier, that neither the Partnership nor the Master Fund will be subject to any income, withholding,

nture capital, special situations, turnaround, mezzanine, distressed opportunities, real estate and infrastructure assets on the secondary market. The Master Fund is managed by Deutsche Alternative Asset Management (Global) Limited (the "Master Fund Manager"), an affiliate of Deutsche Bank AG ("Deutsche Bank"