Contract analysis

I. Description of Entity and Purpose of Election The following information is provided as a supporting statement to the Form 8832 filed on behalf of Solara International Feeder (Cayman) LP: Purpose of the Entity. Solara International Feeder (Cayman) LP is being formed as a feeder vehicle for non-U.S. investors investing into Solara Consolidated Master Fund LP, a Delaware limited partnership that is also to be formed

II. Relationship to Other Entity Classification Elections Filed Concurrently This Form 8832 is being filed concurrently with the following additional entity classification elections, each of which shares the same requested effective date of September 15, 2025:

1. Form 8832 for Solara Consolidated Master Fund LP — A newly formed Delaware limited partnership electing to be classified as a partnership for United States federal income tax purposes. The Consolidated Master Fund LP serves as the central investment vehicle in the reorganized fund structure and will receive the assets and liabilities of the four legacy offshore parallel fund vehicles.

2. Form 8832 for Solara Tax-Exempt Feeder (Cayman) LP — A newly formed Cayman Islands exempted limited partnership electing to be classified as a partnership for United States federal income tax purposes. The Tax-Exempt Feeder serves as the vehicle through which U.S. tax-exempt investors (including pension funds, endowments, and foundations) will invest into the Consolidated Master Fund LP, providing a structure desi

III. Confirmation of Eligible Entity Status Solara International Feeder (Cayman) LP is an "eligible entity" within the meaning of Treas. Reg. § 301.7701-3(a). An eligible entity is a business entity that is not classified as a corporation under Treas. Reg. § 301.7701-2(b)(1), (3), (4), (5), (6), (7), or (8). In particular, Treas. Reg. § 301.7701-2(b)(8) sets forth a list of certain foreign business entities that are