Contract analysis

Section 1: Purpose of Payment This document serves as Calderwood & Harkness LLP's internal record confirming the wire transfer of the Internal Revenue Service ("IRS") user fee in connection with the private letter ruling ("PLR") request to be submitted on behalf of Solara Digital Infrastructure LP (EIN: 82-4917366) ("Solara" or "SDILP") and its affiliated fund entities, as more fully identified in Section 2 below. Th

Section 2: Taxpayer / Client Information 2.1 Primary Client 2.2 Client Contacts for Billing Purposes The following individuals have been designated by the client as the primary contacts for billing and financial matters relating to this engagement: • Douglas Wexford, Chief Financial Officer, Solara Digital Infrastructure LP • Stefan Dalmqvist, Head of Tax, Solara Digital Infrastructure LP All billing correspondence a

Section 3: Wire Transfer Details 3.1 Payment Amount The payment amount of $38,000.00 corresponds to the full user fee required under Revenue Procedure 2025-1, Appendix A, for the category of ruling request applicable to this matter. No partial payment, installment arrangement, or fee reduction has been requested or approved by the IRS in connection with this submission. 3.2 Date of Wire Initiation and Settlement The

Section 4: Authorization and Approval The wire transfer described in this confirmation was authorized by Sylvia Hartwell, Billing Partner, in her capacity as the billing partner on Engagement No. 20250527-SDILP-PLR. Ms. Hartwell provided written authorization for the disbursement via the firm's electronic disbursement approval system on August 12, 2025, following a review of the applicable IRS fee schedule and confir

Section 5: Responsible Accounting Contact The following individual in Calderwood & Harkness LLP's Accounting Department is the responsible contact for all matters relating to the processing, confirmation, and reconciliation of this wire transfer: Ms. Hwang processed the wire request submitted by the Tax practice group on August 12, 2025, coordinated the transmission of payment instructions to Graystone Trust Company,

Section 6: Accompanying IRS Submission Documents This wire transfer confirmation is being maintained in the engagement file alongside the following related documents pertaining to the PLR request and the IRS submission package. Together, these documents constitute the complete record of the user fee payment and the PLR filing:

1. IRS User Fee Payment Transmittal Letter — Cover letter from Calderwood & Harkness LLP to the Internal Revenue Service accompanying the $38,000.00 user fee payment, referencing Revenue Procedure 2025-1 and identifying the taxpayer as Solara Digital Infrastructure LP (EIN: 82-4917366). The transmittal letter provides wire transfer details to facilitate matching of the payment to the ruling request submission.

2. PLR Submission Transmittal Letter — Formal cover letter accompanying the complete PLR request package to be submitted to the IRS on August 15, 2025, identifying the taxpayer, the subject matter of the ruling request, the applicable Code sections, and the responsible Calderwood & Harkness attorneys.

3. PLR Request — Execution Version — The final, executed version of the private letter ruling request, signed by Viktor Raines in his capacity as Managing Partner and Founder of Solara Digital Infrastructure LP.

4. IRS Form 2848 — Power of Attorney and Declaration of Representative — Executed by Viktor Raines on behalf of Solara Digital Infrastructure LP, designating Leonard Cross (Calderwood & Harkness LLP, 1900 K Street NW, Suite 1100, Washington, DC 20006) as the taxpayer's authorized representative before the IRS.

5. IRS Form 2848 — Power of Attorney and Declaration of Representative — Executed by Viktor Raines on behalf of Solara Digital Infrastructure LP, designating Sylvia Hartwell (Calderwood & Harkness LLP, 600 Lexington Avenue, 38th Floor, New York, NY 10022) as an additional authorized representative before the IRS.

6. Penalties of Perjury Declaration — Declaration signed by Viktor Raines under penalties of perjury, as required by Revenue Procedure 2025-1, attesting to the accuracy and completeness of the facts and representations set forth in the PLR request.

7. PLR Exhibits A through E — Supporting exhibits to the PLR request, including organizational charts, transaction flow diagrams, pro forma partnership agreement provisions, financial projections, and summaries of applicable foreign law. The complete PLR request package, inclusive of the foregoing documents, is to be submitted to the IRS at the following address: Internal Revenue Service Attn: CC:INTL 1111 Constituti

Section 7: Rev. Proc. 2025-1 Fee Schedule Reference The user fee amount of $38,000.00 was determined by reference to Revenue Procedure 2025-1, 2025-1 I.R.B. 1, Appendix A — Schedule of User Fees. The applicable fee category under the Schedule of User Fees is for ruling requests involving multiple entities with combined assets exceeding $50 million. As noted above, the combined net asset value of the Solara fund entit

Section 8: File Copy and Distribution Copies of this wire transfer confirmation have been filed and distributed as follows: An additional copy of this wire transfer confirmation will be transmitted to the client — specifically, to Stefan Dalmqvist, Head of Tax, Solara Digital Infrastructure LP — together with the next monthly invoice issued by the firm for this engagement, as supporting documentation for the $38,000.

Section 9: Preparer Attestation and Approval I, Garrett Simmons, confirm that the information set forth in this wire transfer confirmation is accurate and complete to the best of my knowledge as of the date indicated below. The wire transfer details contained herein were obtained from the electronic settlement confirmation provided by Graystone Trust Company, N.A. and verified against the firm's wire transfer log and