Contract analysis

I. Introduction and Purpose Calderwood & Harkness LLP respectfully submits this transmittal letter and the accompanying enclosed materials on behalf of its client, Solara Digital Infrastructure LP ("Solara" or "SDILP"), a Delaware limited partnership (Employer Identification Number: 82-4917366), with its principal offices located at 1200 Market Street, Suite 3400, Wilmington, Delaware 19801. Calderwood & Harkness LLP

II. Identification of Taxpayer and Related Entities A. Principal Taxpayer The principal taxpayer on whose behalf this ruling request is submitted is Solara Digital Infrastructure LP (EIN: 82-4917366), a Delaware limited partnership formed on March 17, 2014, under the Delaware Revised Uniform Limited Partnership Act, 6 Del. C. §§ 17-101 et seq. As of March 31, 2025, Solara has approximately $14.7 billion in assets und

1. Solara Digital Partners Fund IV LP (EIN: 85-2103748) — A Delaware limited partnership with a fund size of approximately $4.2 billion (vintage 2021). As of March 31, 2025, Fund IV is approximately 72% deployed across eleven portfolio company investments in the digital infrastructure and enterprise software sectors. The general partner of Fund IV LP is Solara Digital Infrastructure GP LLC (EIN: 82-4917365).

2. Solara Digital Partners Fund IV-A (Cayman) LP (EIN: 98-6241503) — A Cayman Islands exempted limited partnership with a fund size of approximately $1.85 billion, serving as the primary offshore parallel vehicle for Fund IV. Fund IV-A (Cayman) LP maintains its registered office at Harborstone Corporate Services Ltd., P.O. Box 2714, 94 Solaris Avenue, George Town, Grand Cayman KY1-1111, Cayman Islands. The general pa

3. Solara Digital Partners Fund IV-B (Luxembourg) SCSp (EIN: 98-6241571) — A Luxembourg société en commandite spéciale with a fund size of approximately €1.15 billion (approximately $1.24 billion at an exchange rate of 1.08 EUR/USD), serving as the European parallel vehicle for Fund IV. Fund IV-B (Luxembourg) SCSp maintains its registered office at 14, rue Jean-Pierre Brasseur, L-1258 Luxembourg, Grand Duchy of Luxem

4. Solara Digital Partners Fund V LP (EIN: 88-3467219) — A Delaware limited partnership with a fund size of approximately $5.6 billion (vintage 2023). As of March 31, 2025, Fund V is approximately 38% deployed across twelve portfolio company investments in the digital infrastructure, data center, and software-as-a-service sectors. The general partner of Fund V LP is Solara Digital Infrastructure GP LLC (EIN: 82-49173

5. Solara Digital Partners Fund V-A (Cayman) LP (EIN: 98-7891234) — A Cayman Islands exempted limited partnership with a fund size of approximately $2.45 billion, serving as the primary offshore parallel vehicle for Fund V. Fund V-A (Cayman) LP maintains its registered office at Harborstone Corporate Services Ltd., George Town, Grand Cayman, Cayman Islands. The general partner is Solara Offshore GP Ltd. Fund V-A (Cay

6. Solara Digital Partners Fund V-B (Luxembourg) SCSp (EIN: 98-7891267) — A Luxembourg société en commandite spéciale with a fund size of approximately €1.38 billion (approximately $1.49 billion at an exchange rate of 1.08 EUR/USD), serving as the European parallel vehicle for Fund V. Fund V-B (Luxembourg) SCSp maintains its registered office at 14, rue Jean-Pierre Brasseur, L-1258 Luxembourg, Grand Duchy of Luxembou

1. Solara Consolidated Master Fund GP LLC — A Delaware limited liability company to be formed on or about September 15, 2025. Solara Consolidated Master Fund GP LLC will serve as the general partner of the Consolidated Master Fund LP described below. It is anticipated that Solara Consolidated Master Fund GP LLC will be classified as a disregarded entity for U.S. federal income tax purposes (or, if it has more than on

2. Solara Consolidated Master Fund LP — A Delaware limited partnership to be formed on or about September 15, 2025. The Consolidated Master Fund LP will serve as the master fund vehicle into which the portfolio assets currently held by the four legacy offshore vehicles (Fund IV-A (Cayman) LP, Fund IV-B (Luxembourg) SCSp, Fund V-A (Cayman) LP, and Fund V-B (Luxembourg) SCSp) will be consolidated. The general partner o

3. Solara International Feeder (Cayman) LP — A Cayman Islands exempted limited partnership to be formed in connection with Step 5 of the Reorganization. The International Feeder will serve as the feeder vehicle through which non-U.S. investors will invest, indirectly, in the Consolidated Master Fund LP. The International Feeder is intended to be classified as a partnership for U.S. federal income tax purposes under T

4. Solara Tax-Exempt Feeder (Cayman) LP — A Cayman Islands exempted limited partnership to be formed in connection with Step 5 of the Reorganization. The Tax-Exempt Feeder will serve as the feeder vehicle through which U.S. tax-exempt investors will invest, indirectly, in the Consolidated Master Fund LP. The Tax-Exempt Feeder is designed to mitigate concerns regarding unrelated business taxable income ("UBTI") under

III. Summary of Proposed Transaction The Reorganization consists of a carefully sequenced, five-step transaction designed to consolidate the portfolio assets of Solara's existing offshore fund vehicles into the newly formed Consolidated Master Fund LP, while simultaneously establishing feeder vehicles to accommodate the differing tax profiles of Solara's diverse investor base. The following is a summary of each step,

IV. Summary of Rulings Requested The enclosed private letter ruling request seeks the following eight specific rulings from the Service: Ruling 1 — Nonrecognition Under IRC § 721(a). The contributions of portfolio assets by each of the legacy offshore vehicles (Fund IV-A (Cayman) LP, Fund IV-B (Luxembourg) SCSp, Fund V-A (Cayman) LP, and Fund V-B (Luxembourg) SCSp) to the Consolidated Master Fund LP in exchange for l

V. Reference to Pre-Submission Conference A pre-submission conference was held on Tuesday, July 22, 2025, at the offices of the Internal Revenue Service, 1111 Constitution Avenue NW, Washington, DC 20224, with representatives of the Office of the Associate Chief Counsel (International), CC:INTL, Branch 1. Calderwood & Harkness LLP was represented at the pre-submission conference by the following individuals: • Leonar

VI. Schedule of Enclosed Documents The following documents are enclosed with this transmittal letter as part of the complete ruling request submission package:

1. PLR Request — Execution Version. Signed private letter ruling request, including the complete statement of facts, a detailed legal analysis supporting each of the eight rulings requested, and all taxpayer representations required by Rev. Proc. 2025-1. The PLR request has been signed on behalf of Solara Digital Infrastructure GP LLC, the general partner of Solara Digital Infrastructure LP, by Viktor Raines, Managin

2. Exhibit A — Organizational Charts (Pre-Reorganization). Diagrams depicting the current organizational structure of all six Solara fund vehicles (Fund IV LP, Fund IV-A (Cayman) LP, Fund IV-B (Luxembourg) SCSp, Fund V LP, Fund V-A (Cayman) LP, and Fund V-B (Luxembourg) SCSp), their respective general partners, the ownership and management relationships among them, and their portfolio company holdings.

3. Exhibit B — Organizational Charts (Post-Reorganization). Diagrams depicting the target post-reorganization organizational structure, including the Consolidated Master Fund LP, the International Feeder (Cayman) LP, the Tax-Exempt Feeder (Cayman) LP, the co-investing Delaware funds (Fund IV LP and Fund V LP), and their respective general partners and investor flows.

4. Exhibit C — Step Transaction Diagrams. Visual depictions of each of the five reorganization steps (Steps 1 through 5), including entity relationships, the direction and nature of asset flows and consideration exchanged at each step, and cross-references to the applicable provisions of the Internal Revenue Code and Treasury Regulations.

5. Exhibit D — Schedule of Contributing Entities and Assets. A tabular schedule setting forth each contributing entity, each portfolio company asset to be transferred, the fair market value and adjusted tax basis of each asset, the built-in gain attributable to each asset, and the percentage ownership interest held in each portfolio company. The schedule reflects aggregate totals of approximately $7.75 billion in fai

6. Exhibit E — Schedule of Liabilities and § 752 Analysis. A detailed schedule of pre-reorganization and post-reorganization allocations of the aggregate $1.34 billion in liabilities, including a step-by-step analysis of deemed contributions and deemed distributions under IRC §§ 752(a) and 752(b), the application of the netting rule under Treasury Regulation § 1.752-1(f), and the treatment of liabilities in the tiere

7. IRS Form 2848 — Power of Attorney (Leonard Cross). IRS Form 2848 designating Leonard Cross, Calderwood & Harkness LLP, 1900 K Street NW, Suite 1100, Washington, DC 20006, as an authorized representative of Solara Digital Infrastructure LP (EIN: 82-4917366), Solara Digital Infrastructure GP LLC (EIN: 82-4917365), and all fund entities identified in Section II of this transmittal letter, with authority to represent

8. IRS Form 2848 — Power of Attorney (Sylvia Hartwell). IRS Form 2848 designating Sylvia Hartwell, Calderwood & Harkness LLP, 600 Lexington Avenue, 38th Floor, New York, NY 10022, as an authorized representative of all Solara entities identified in Section II of this transmittal letter, with authority to represent such entities before the Internal Revenue Service in connection with this ruling request.

9. Penalties of Perjury Declaration. Declaration signed by Viktor Raines, in his capacity as Managing Partner of Solara Digital Infrastructure GP LLC, the general partner of Solara Digital Infrastructure LP, declaring under penalties of perjury that the facts presented in the ruling request are true, correct, and complete to the best of the declarant's knowledge and belief.

10. IRS User Fee Wire Transfer Confirmation. Confirmation of the payment of the applicable user fee in the amount of $38,000, transmitted by wire transfer to the Internal Revenue Service, in accordance with the Schedule of User Fees set forth in Appendix A to Rev. Proc. 2025-1 (applicable to a ruling request involving multiple entities with combined assets exceeding $50 million).

VII. Authorized Representatives and Contact Information All correspondence and communications from the Service regarding this ruling request should be directed to the following authorized representatives: Leonard Cross Responsible Partner, Tax Calderwood & Harkness LLP 1900 K Street NW, Suite 1100 Washington, DC 20006 Telephone: (202) 555-7418 Facsimile: (202) 555-7401 Email: lcross@calderwoodharkness.com Sylvia Hart

VIII. IRS User Fee Confirmation We hereby confirm that the applicable user fee in the amount of $38,000 has been paid by wire transfer to the Internal Revenue Service in connection with this private letter ruling request. A copy of the wire transfer confirmation is enclosed as Enclosure 10 to this submission. The user fee amount has been calculated in accordance with the Schedule of User Fees set forth in Appendix A

IX. Request for Expedited Handling Solara respectfully requests that the Service consider this private letter ruling request on an expedited basis to the extent practicable, in light of the time-sensitive nature of the proposed Reorganization. The Reorganization is structured as a five-step transaction with target effective dates commencing on September 15, 2025 (Step 1 — Formation of New Entities) and concluding on

X. Closing We are prepared to provide any additional information, documentation, supplemental representations, or clarification that the Service may require in connection with its consideration of this private letter ruling request. We are likewise available for a conference at the Service's offices or a telephone call at the Service's convenience to discuss any aspect of the submission. We appreciate the Service's a