Contract analysis

1. Solara Digital Partners Fund IV-A (Cayman) LP — Cayman Islands exempted limited partnership (EIN: 98-6241503). Contribution of assets expected on October 1, 2025 (Step 2).

2. Solara Digital Partners Fund IV-B (Luxembourg) SCSp — Luxembourg special limited partnership (société en commandite spéciale) (EIN: 98-6241571). Contribution of assets expected on October 15, 2025 (Step 3).

3. Solara Digital Partners Fund V-A (Cayman) LP — Cayman Islands exempted limited partnership (EIN: 98-7891234). Contribution of assets expected on November 1, 2025 (Step 4).

4. Solara Digital Partners Fund V-B (Luxembourg) SCSp — Luxembourg special limited partnership (société en commandite spéciale) (EIN: 98-7891267). Contribution of assets expected on November 1, 2025 (Step 4). Following the completion of Step 5 of the reorganization (expected December 1, 2025), the limited partner interests in Solara Consolidated Master Fund LP will transition to include the following newly formed fee

II. Business Purpose Solara Consolidated Master Fund LP is being formed as the master fund vehicle in a cross-border reorganization of the Solara Digital Infrastructure LP fund platform (the "Reorganization"). The purpose of the Reorganization is to consolidate the portfolio assets currently held by four legacy offshore fund vehicles into a single domestic master fund structure, in order to simplify the fund platform

1. Solara Digital Partners Fund IV-A (Cayman) LP — a Cayman Islands exempted limited partnership formed in 2019. Fund IV-A holds a diversified portfolio of investments in digital infrastructure and enterprise SaaS companies, primarily through equity and equity-linked instruments.

2. Solara Digital Partners Fund IV-B (Luxembourg) SCSp — a Luxembourg special limited partnership (société en commandite spéciale) formed in 2019. Fund IV-B holds investments substantially similar to those held by Fund IV-A, structured through Luxembourg for European investor access and regulatory purposes.

3. Solara Digital Partners Fund V-A (Cayman) LP — a Cayman Islands exempted limited partnership formed in 2022. Fund V-A represents the successor fund generation and holds investments in later-stage digital infrastructure assets and growth-stage SaaS platforms.

4. Solara Digital Partners Fund V-B (Luxembourg) SCSp — a Luxembourg special limited partnership (société en commandite spéciale) formed in 2022. Fund V-B holds investments substantially similar to those held by Fund V-A, structured through Luxembourg for European investor access and regulatory purposes. Aggregate Asset Information. The following table summarizes the aggregate asset values and other financial informa

1. Veridian Edge Computing Corp. — a Delaware corporation engaged in the development, deployment, and operation of edge computing infrastructure and services. Fair market value: $1.12 billion.

2. NovaBright Data Systems Inc. — a Delaware corporation engaged in the ownership, development, and operation of hyperscale data center facilities across North America and Western Europe. Fair market value: $890 million.

3. Thorngate Fiber Networks LP — a Delaware limited partnership engaged in the construction, operation, and leasing of fiber-optic network infrastructure in major metropolitan areas. Fair market value: $670 million.

4. Helix SaaS Holdings Ltd. — a Cayman Islands exempted company serving as a holding company for a portfolio of enterprise SaaS businesses across multiple verticals. Fair market value: $445 million.

5. Crestline Cloud Solutions LLC — a Delaware limited liability company engaged in the development and operation of a cloud-based SaaS platform for enterprise resource planning and workflow automation. Fair market value: €340 million (approximately $367 million at current exchange rates). The remaining 18 portfolio companies represent investments ranging from approximately $35 million to $310 million in fair market v

III. Reorganization Transaction Steps The formation of Solara Consolidated Master Fund LP and the filing of this Form 8832 election are part of a coordinated multi-step reorganization. The anticipated transaction steps and their expected dates are as follows: Step 1 — Formation of New Entities (September 15, 2025): Formation of Solara Consolidated Master Fund GP LLC (general partner) and Solara Consolidated Master Fu

IV. Coordination with Private Letter Ruling Request This Form 8832 election is being filed as part of a coordinated tax planning strategy for which Solara Digital Infrastructure LP has engaged Calderwood & Harkness LLP (engagement number 20250527-SDILP-PLR) to prepare and submit a private letter ruling ("PLR") request to the Internal Revenue Service, Office of the Associate Chief Counsel (International). The PLR requ

V. Related Form 8832 Elections Two additional Form 8832 elections are being filed concurrently (or will be filed promptly following formation) for related entities formed as part of the same Reorganization:

1. Solara International Feeder (Cayman) LP — a Cayman Islands exempted limited partnership to be formed in connection with Step 5 of the Reorganization. This entity will elect to be classified as a partnership for U.S. federal income tax purposes under Treasury Regulations section 301.7701-3. The entity will serve as the feeder vehicle through which non-U.S. investors hold indirect interests in Solara Consolidated Ma

2. Solara Tax-Exempt Feeder (Cayman) LP — a Cayman Islands exempted limited partnership to be formed in connection with Step 5 of the Reorganization. This entity will elect to be classified as a partnership for U.S. federal income tax purposes under Treasury Regulations section 301.7701-3. The entity will serve as the feeder vehicle through which U.S. tax-exempt investors (including pension funds, endowments, foundat

VI. Regulatory References The following regulatory provisions are relevant to this Form 8832 election: • Treas. Reg. § 301.7701-3(a): Solara Consolidated Master Fund LP is an "eligible entity" within the meaning of this regulation — that is, a business entity that is not classified as a corporation under Treasury Regulations section 301.7701-2(b). A Delaware limited partnership is not included in the list of per se c

1. Original: Filed with the IRS Service Center at the address above.

2. Tax Return Copy: One copy of the filed Form 8832 (including the confirmation letter received from the IRS, if any) must be attached to the entity's initial federal income tax return. Because Solara Consolidated Master Fund LP is electing partnership classification, the initial return will be Form 1065, U.S. Return of Partnership Income, for the short tax year beginning September 15, 2025 and ending December 31, 20

3. Engagement File Copy: The original executed Form 8832 and the IRS confirmation letter (when received) should be maintained in the Calderwood & Harkness LLP engagement files under matter number 20250527-SDILP-PLR. Both the Washington, D.C. and New York offices should retain copies.

4. Client Records: A copy of the executed Form 8832 and IRS confirmation should be provided to the client for inclusion in the permanent tax records of Solara Digital Infrastructure LP and Solara Consolidated Master Fund LP. Responsible Attorneys. Garrett Simmons, Working Associate in the New York office, has primary responsibility for the preparation, review, and filing of this Form 8832, under the supervision of Le