EFTA Document EFTA01386203

AGP LP 519 Alpha Group Capital Paul Barrett A Foreign Partner generally will not be subject to any United States Federal income tax on his share of the Partnership's capital gains to the extent that such gains are not derived from "United States real property interests" within the meaning of Section 897 of the Code (which term includes, among other things, direct interests in real property and certain securities). A Foreign Partner generally will not be subject to any United States Federal