Contract analysis

1. Sponsor and Management Entity Solara Digital Infrastructure LP — A Delaware limited partnership (EIN: 82-4917366). Solara Digital Infrastructure LP serves as the sponsor and management entity for the Solara Fund Platform. As of March 31, 2025, the Solara Fund Platform had aggregate assets under management ("AUM") of approximately $14.7 billion across all fund vehicles. Solara Digital Infrastructure LP provides inv

2. General Partner — Management Level Solara Digital Infrastructure GP LLC — A Delaware limited liability company (EIN: 82-4917365). Solara Digital Infrastructure GP LLC serves as the general partner of Solara Digital Infrastructure LP and is managed by Viktor Raines, Managing Partner. Solara Digital Infrastructure GP LLC also serves as the general partner of the U.S. domestic fund vehicles described below (Fund IV L

3. Fund IV Vehicles (a) Solara Digital Partners Fund IV LP — A Delaware limited partnership (EIN: 85-2103748). Fund IV LP has total commitments of $4.2 billion, vintage year 2021, and is approximately 72% deployed as of the date hereof. The general partner of Fund IV LP is Solara Digital Infrastructure GP LLC. Fund IV LP serves as the primary investment vehicle for U.S. taxable investors participating in the Fund IV

4. Fund V Vehicles (a) Solara Digital Partners Fund V LP — A Delaware limited partnership (EIN: 88-3467219). Fund V LP has total commitments of $5.6 billion, vintage year 2023, and is approximately 38% deployed as of the date hereof. The general partner of Fund V LP is Solara Digital Infrastructure GP LLC. Fund V LP serves as the primary investment vehicle for U.S. taxable investors participating in the Fund V invest

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 Solara Consolidated Master Fund LP. It will be wholly owned by Solara Digital Infrastructure GP LLC and will be managed by Viktor Raines, Managing Partner. An application for an employer identification number will be fi

2. Solara Consolidated Master Fund LP A Delaware limited partnership, to be formed on or about September 15, 2025. Solara Consolidated Master Fund LP (the "Consolidated Master Fund") will serve as the master fund vehicle consolidating all offshore vehicle portfolio assets following the completion of the Reorganization. The general partner of the Consolidated Master Fund will be Solara Consolidated Master Fund GP LLC.

3. Solara International Feeder (Cayman) LP A Cayman Islands exempted limited partnership, to be formed on or about September 15, 2025. Solara International Feeder (Cayman) LP (the "International Feeder") will serve as the feeder vehicle through which non-U.S. investors invest into the Consolidated Master Fund. The limited partners of the International Feeder will include, among others, Nordhaven Sovereign Wealth Fund

4. Solara Tax-Exempt Feeder (Cayman) LP A Cayman Islands exempted limited partnership, to be formed on or about September 15, 2025. Solara Tax-Exempt Feeder (Cayman) LP (the "Tax-Exempt Feeder") will serve as the feeder vehicle through which U.S. tax-exempt investors invest into the Consolidated Master Fund, in order to provide such investors with continued protection against UBTI exposure. The limited partners of th

Section 1446 Withholding Analysis: To the extent that Fund IV-B (Luxembourg) SCSp is treated as a foreign person engaged in a trade or business within the United States through the partnership, the PLR Request addresses the withholding obligations under IRC § 1446 and concludes that the contribution does not give rise to gain that would be subject to withholding under § 1446(a) because the contribution is treated as

Section 752(a) Deemed Contributions and Section 752(b) Deemed Distributions Analysis The Reorganization will result in changes to each partner's share of partnership liabilities, as the liabilities currently allocated through the legacy offshore vehicles will be reallocated through the new tiered master-feeder structure. Under IRC § 752(a), any increase in a partner's share of partnership liabilities is treated as a