Contract analysis

1. Private Letter Ruling Request, dated September 22, 2025, together with all exhibits thereto, including the penalties-of-perjury declaration required by Section 7.01(16) of Revenue Procedure 2025-1, executed by Jonathan M. Hirota, Vice President, Tax, on behalf of Fairwater Real Estate Investment Trust;

2. IRS Form 2848 (Power of Attorney and Declaration of Representative), dated September 22, 2025, designating Sylvia Hartwell (PTIN: P01882447) and Garrett Simmons (PTIN: P02094518), each of Calderwood & Harkness LLP, as authorized representatives of Fairwater in connection with this Ruling Request;

3. User fee check — Ridgeline National Bank, N.A., check no. 00471826, in the amount of $38,000.00, payable to "United States Treasury";

4. Copy of Fairwater's Articles of Trust, as amended and restated through August 15, 2023, filed with the State Department of Assessments and Taxation of Maryland;

5. Organizational chart depicting the current corporate and entity structure of Fairwater and its subsidiaries, together with the proposed subsidiary structure following the formation of Fairwater Southgate TRS, Inc. and the consummation of the Southgate Portfolio acquisition;

6. Summary of Southgate Portfolio properties, consisting of eleven (11) mixed-use properties located across the Commonwealth of Virginia, the State of North Carolina, and the State of Georgia, comprising approximately 3.1 million rentable square feet of commercial, retail, and residential space;

7. Summary of arm's-length rent appraisal prepared by Caldwell Valuation Group, LLC, an independent real estate valuation firm, dated August 30, 2025, supporting the arm's-length character of the proposed intercompany lease rents between Fairwater and Fairwater Southgate TRS, Inc.;

8. Proposed form of intercompany lease (Fairwater, as Landlord, to Fairwater Southgate TRS, Inc., as Tenant), in substantially final form, subject to such modifications as may be necessary in connection with final structuring of the Southgate Portfolio acquisition; and

9. REIT qualification metrics schedule, setting forth Fairwater's projected post-acquisition asset composition, gross income composition, and distribution requirements, demonstrating anticipated compliance with the asset, income, and distribution tests applicable to real estate investment trusts under Sections 856 through 860 of the Code. Shipment Details The complete ruling-request package, including this transmitta

1. Private Letter Ruling Request (with all exhibits and penalties-of-perjury declaration)

2. IRS Form 2848 (Power of Attorney and Declaration of Representative)

3. User fee check — Ridgeline National Bank, N.A., check no. 00471826 ($38,000.00)

4. Copy of Fairwater's Articles of Trust

5. Organizational chart (current and proposed subsidiary structure)

6. Summary of Southgate Portfolio properties

7. Summary of Caldwell Valuation Group, LLC arm's-length rent appraisal (August 30, 2025)

8. Proposed form of intercompany lease (Fairwater to Fairwater Southgate TRS, Inc.)

9. REIT qualification metrics schedule cc: Jonathan M. Hirota, Vice President, Tax, Fairwater Real Estate Investment Trust Anita Bashar Reeves, General Counsel, Fairwater Real Estate Investment Trust Garrett Simmons, Calderwood & Harkness LLP Leila Nazari, Calderwood & Harkness LLP Leonard Cross, Calderwood & Harkness LLP