Contract analysis

I. FEDERAL INCOME TAX RETURNS AND CORRESPONDENCE 1.1 Copies of all federal income tax returns (including, without limitation, IRS Forms 1120, 1120-S, 1065, and all schedules, statements, and attachments thereto) filed by CBR and each of its direct and indirect subsidiaries for fiscal years ended December 31, 2019, December 31, 2020, and December 31, 2021. This request includes any amended returns (e.g., Forms 1120-X)

II. STATE AND LOCAL TAX RETURNS AND CORRESPONDENCE 2.1 Copies of all state and local income, franchise, gross receipts, margin, and similar tax returns filed by CBR and each of its subsidiaries for fiscal years ended December 31, 2019, December 31, 2020, and December 31, 2021, in each jurisdiction where such returns were filed. This request encompasses, without limitation, the following jurisdictions and tax types: (

III. ENTITY CLASSIFICATION AND TAX STRUCTURE 3.1 A comprehensive schedule of all entities in the CBR organizational structure, including, for each entity: (a) legal name; (b) entity type (corporation, limited liability company, limited partnership, general partnership, or other); (c) jurisdiction of formation; (d) date of formation; (e) federal tax classification (C-corporation, S-corporation, disregarded entity, or

IV. TAX-EQUITY PARTNERSHIPS AND STRUCTURES 4.1 Copies of all partnership agreements, limited liability company operating agreements, and all amendments, supplements, and side letters thereto, governing tax-equity investment structures involving CBR or any of its subsidiaries, including, without limitation: (a) the amended and restated limited liability company agreement (or equivalent governing document) for Solaris

V. INVESTMENT TAX CREDIT (ITC) AND PRODUCTION TAX CREDIT (PTC) 5.1 A comprehensive schedule of all investment tax credit ("ITC") and production tax credit ("PTC") claims made by or on behalf of CBR and its subsidiaries, organized by project, including, for each project: (a) the type of credit claimed (ITC under Section 48 or PTC under Section 45); (b) the credit rate claimed (e.g., 30% ITC, full PTC rate, or reduced

VI. SECTION 409A VALUATIONS AND EQUITY COMPENSATION TAX MATTERS 6.1 Copies of all independent valuations of CBR common stock prepared for purposes of Section 409A of the Internal Revenue Code of 1986, as amended (the "Code"), from the date of the earliest outstanding equity award through the most recent valuation date, including, for each valuation: (a) the name of the valuation firm engaged; (b) the valuation date;

VII. TAX-SHARING, TAX-INDEMNITY, AND TAX-ALLOCATION AGREEMENTS 7.1 Copies of all tax-sharing agreements, tax-allocation agreements, and tax-indemnity agreements (whether freestanding or embodied in provisions of operating agreements, stockholders' agreements, or similar governing documents) among CBR and its subsidiaries, or between CBR or any subsidiary and any third party, including, without limitation, Pinnacle Vi

VIII. TRANSFER PRICING AND INTERCOMPANY TRANSACTIONS 8.1 A description of all material intercompany transactions among CBR and its subsidiaries during the review period, including, without limitation: (a) management fees or administrative fees charged by CBR or any subsidiary to another member of the group; (b) cost allocations for shared services (e.g., accounting, human resources, information technology, legal, and

IX. TAX RESERVES, UNCERTAIN TAX POSITIONS, AND CONTINGENCIES 9.1 A schedule of all tax reserves and uncertain tax positions reported under ASC 740-10 (formerly FIN 48, "Accounting for Uncertainty in Income Taxes") as of December 31, 2019, December 31, 2020, December 31, 2021, and March 31, 2022 (to the extent available), including, for each uncertain tax position: (a) a description of the underlying tax position; (b)

X. DEPRECIATION, AMORTIZATION, AND COST-SEGREGATION 10.1 Copies of all cost-segregation studies performed for any project, facility, office, or other property owned or leased by CBR or any of its subsidiaries, including the name of the firm that prepared each study, the date of the study, the property or project covered, and the conclusions regarding classification of assets by MACRS recovery period. 10.2 A schedule

XI. SALES, USE, PROPERTY, AND OTHER NON-INCOME TAXES 11.1 A schedule of all sales and use tax exemptions claimed by CBR or any of its subsidiaries during the review period, including, for each exemption: (a) the jurisdiction; (b) the type of exemption (e.g., manufacturing exemption, utility exemption, resale exemption, renewable-energy exemption, government-contract exemption); (c) the statutory or regulatory basis f

XII. INTERNATIONAL TAX MATTERS 12.1 A description of any foreign operations, foreign subsidiaries, foreign branches, foreign disregarded entities, or foreign investments held directly or indirectly by CBR or any of its subsidiaries, including the name, jurisdiction of organization, and nature of activities of each foreign entity or operation. 12.2 Copies of any IRS Forms 5471 (Information Return of U.S. Persons With

XIII. TAX MATTERS RELATED TO THE PROPOSED IPO 13.1 Copies of any analyses, memoranda, or other materials regarding the tax consequences of the pre-IPO corporate reorganization or reclassification of equity, including, without limitation: (a) the conversion of preferred stock, convertible notes, or other equity instruments into common stock; (b) the reclassification, stock split, or similar transaction necessary to ac

XIV. MISCELLANEOUS TAX MATTERS 14.1 Copies of all powers of attorney (IRS Forms 2848, Power of Attorney and Declaration of Representative) and tax information authorizations (IRS Forms 8821) currently on file with the IRS or any state or local taxing authority on behalf of CBR or any of its subsidiaries. 14.2 A schedule of all tax return preparers, tax advisors, and tax consultants engaged by CBR or any of its subsid