Contract analysis

I. COVER MEMORANDUM MEMORANDUM TO: Marcus Pellegrino, Partner, Healthcare Ardent Capital Partners III LP 600 Lexington Avenue, 38th Floor New York, NY 10022 FROM: Leonard Cross, Partner, Tax Robert Jansen, Senior Associate, Tax Calderwood & Harkness LLP One Liberty Plaza, 45th Floor New York, NY 10006 DATE: May 31, 2024 RE: Draft Section 754 Election Statement — Pinnacle Health Services Group LLC (EIN 82-1947632) Dea

II. ELECTION STATEMENT — SECTION 754 A. Formal Caption ELECTION UNDER SECTION 754 OF THE INTERNAL REVENUE CODE Partnership Name: Pinnacle Health Services Group LLC Employer Identification Number: 82-1947632 Principal Office Address: 2200 Renaissance Boulevard, Suite 400, King of Prussia, Pennsylvania 19406 Taxable Year for Which Election is Made: Taxable year ending December 31, 2024 Entity Type: Delaware limited lia

Section 743(b) Basis Adjustment: The Section 743(b) adjustment of $224,400,000 is a transferee-specific adjustment that is personal to Ardent Healthcare Intermediate Inc. and is allocated among the Partnership's assets in accordance with Section 755 of the Code and Treasury Regulations Section 1.755-1, as described in Section E below. This adjustment does not affect the common basis of the Partnership's assets; rathe

III. FILING INSTRUCTIONS AND PROCEDURAL REQUIREMENTS A. Filing Requirements The Section 754 election statement set forth in Section II above must be filed in compliance with the following procedural requirements:

1. Attachment to Timely Filed Return. The election statement must be attached to a timely filed Form 1065, U.S. Return of Partnership Income, for the taxable year ending December 31, 2024. For this purpose, a return is considered timely filed if it is filed on or before the due date of the return (March 15, 2025) or, if the Partnership has obtained an automatic six-month extension of time to file by timely filing For

2. Signature by Authorized Partner. The election statement must be signed by any one of the partners of the Partnership who is authorized to sign the Partnership's return. Under the Amended and Restated Operating Agreement of Pinnacle, effective as of May 31, 2024, Ardent Healthcare Intermediate Inc. is the sole member and managing member of Pinnacle. Accordingly, the election statement should be signed by a duly aut

3. Partnership Representative. For purposes of the centralized partnership audit regime enacted by the Bipartisan Budget Act of 2015 (the "BBA"), the Partnership must designate a partnership representative for the taxable year ending December 31, 2024, on its Form 1065. It is expected that the partnership representative will be Ardent Healthcare Intermediate Inc., acting through a designated individual to be named on

Section 83(b) Elections. Separate and apart from the Section 754 election addressed herein, certain rollover equity participants in the transaction — specifically, Dr. Raymond Carvallo, Dr. Nadia Ostrowski, and Jonathan Farnsworth (collectively, the "Rollover Participants") — are required to file elections under Section 83(b) of the Code with the Internal Revenue Service on or before June 30, 2024 (within 30 days aft

IV. SIGNATURE BLOCK [To be executed in connection with the filing of the Form 1065 for the taxable year ending December 31, 2024.] The undersigned, being duly authorized to sign the federal income tax return of Pinnacle Health Services Group LLC (EIN 82-1947632) for the taxable year ending December 31, 2024, hereby certifies that Pinnacle Health Services Group LLC elects, pursuant to Section 754 of the Internal Reven

V. APPENDICES / ATTACHMENTS REFERENCED The following appendices and attachments are referenced in this election statement and should be attached to or maintained with the Partnership's records in support of the Section 754 election and the Section 743(b) basis adjustment: Appendix A — Purchase Price Allocation Schedule (dated April 18, 2024) A detailed asset-by-asset allocation of the Section 743(b) basis adjustment

VI. DISCLAIMER AND PRIVILEGE NOTICE This draft election statement and the accompanying cover memorandum have been prepared by Calderwood & Harkness LLP, One Liberty Plaza, 45th Floor, New York, New York 10006 (Engagement No. 1001-00006; Matter No. 1001-00006), by Robert Jansen, Senior Associate, Tax Department, under the supervision of Leonard Cross, Partner, Tax Department. ATTORNEY-CLIENT PRIVILEGED AND CONFIDENTIA

Section 743(b) Basis Adjustment | $224,400,000 Asset Class | Description | Fair Market Value | Existing Inside Basis | Section 743(b) Adjustment | Useful Life Class I | Cash and Cash Equivalents, Bank Deposits | $8,700,000 | $8,700,000 | $0 | N/A Class III | Accounts Receivable, Accrued Revenue, Inventory and Supplies | $32,400,000 | $32,400,000 | $0 | Short-term Class IV | Tangible Depreciable Personal Property (med