Contract analysis

I. BACKGROUND AND SCOPE OF REORGANIZATION The following summary is provided for context to assist Caldwell Pierce in identifying responsive documents and data. It is not intended to be a comprehensive description of the Reorganization, which will be set forth in detail in the PLR submission itself. Solara Digital Infrastructure LP is a Delaware limited partnership formed on March 17, 2014, with assets under managemen

II. IDENTIFICATION OF FUND VEHICLES COVERED BY THIS REQUEST For purposes of this data request, the term "Fund Vehicles" refers collectively to the six fund entities identified below, organized by fund complex. References to "Fund IV Vehicles" mean the three entities listed under subsection A, and references to "Fund V Vehicles" mean the three entities listed under subsection B. A. Fund IV Complex

1. Solara Digital Partners Fund IV LP • Jurisdiction: Delaware limited partnership • EIN: 85-2103748 • Fund Size: $4.2 billion (vintage 2021; approximately 72% deployed as of March 31, 2025) • General Partner: Solara Digital Infrastructure GP LLC • Registered Agent: Pemberton Industries, 251 Little Falls Drive, Wilmington, DE 19808

2. Solara Digital Partners Fund IV-A (Cayman) LP • Jurisdiction: Cayman Islands exempted limited partnership • U.S. EIN: 98-6241503 • CIMA Registration: MF-72491 • Registered Office: Harborstone Corporate Services Ltd., P.O. Box 2714, 94 Solaris Avenue, George Town, Grand Cayman KY1-1111 • Fund Size: $1.85 billion • General Partner: Solara Offshore GP Ltd.

3. Solara Digital Partners Fund IV-B (Luxembourg) SCSp • Jurisdiction: Luxembourg special limited partnership (société en commandite spéciale) • U.S. EIN: 98-6241571 • Luxembourg RCS Number: B 248193 • Registered Office: 14, rue Jean-Pierre Brasseur, L-1258 Luxembourg • Fund Size: €1.15 billion (approximately $1.24 billion at EUR/USD 1.08) • General Partner: Solara Luxembourg Management S.à r.l. (RCS B 248194) B. Fun

4. Solara Digital Partners Fund V LP • Jurisdiction: Delaware limited partnership • EIN: 88-3467219 • Fund Size: $5.6 billion (vintage 2023; approximately 38% deployed as of March 31, 2025) • General Partner: Solara Digital Infrastructure GP LLC • Registered Agent: Pemberton Industries, 251 Little Falls Drive, Wilmington, DE 19808

5. Solara Digital Partners Fund V-A (Cayman) LP • Jurisdiction: Cayman Islands exempted limited partnership • U.S. EIN: 98-7891234 • CIMA Registration: MF-89103 • Registered Office: Harborstone Corporate Services Ltd., P.O. Box 2714, 94 Solaris Avenue, George Town, Grand Cayman KY1-1111 • Fund Size: $2.45 billion • General Partner: Solara Offshore GP Ltd.

6. Solara Digital Partners Fund V-B (Luxembourg) SCSp • Jurisdiction: Luxembourg special limited partnership (société en commandite spéciale) • U.S. EIN: 98-7891267 • Luxembourg RCS Number: B 271056 • Registered Office: 14, rue Jean-Pierre Brasseur, L-1258 Luxembourg • Fund Size: €1.38 billion (approximately $1.49 billion at EUR/USD 1.08) • General Partner: Solara Luxembourg Management S.à r.l. (RCS B 248194) C. Gene

III. REQUESTED DOCUMENTS AND DATA We request that Caldwell Pierce provide the following documents, data, and records for each of the Fund Vehicles identified in Section II. Where a particular request applies to fewer than all six Fund Vehicles, we have so noted. Unless otherwise specified, each request covers the three most recent tax years (2022, 2023, and 2024, or the most recent filed year if 2024 returns have not

1. Complete copies of U.S. federal income tax returns (IRS Form 1065, including all schedules and attachments) for each of the six Fund Vehicles for tax years 2022, 2023, and 2024. If the 2024 returns have not yet been filed or completed, please provide the most recently filed returns and any available draft or work-in-progress versions of the 2024 returns together with an indication of the anticipated filing date.

2. All amendments or supplemental filings (including IRS Form 1065X) to the returns described in paragraph 1 above, for any tax year.

3. Any IRS correspondence related to the six Fund Vehicles received within the last five tax years (2020 through 2024), including but not limited to: (a) Examination or audit letters (including IRS Letter 2205 or equivalent notification of examination); (b) Information document requests ("IDRs") issued by the IRS in connection with any examination; (c) Notices of proposed adjustment ("NOPAs") or revenue agent reports

1. Complete Schedules K-1 (IRS Form 1065) for all partners and limited partners of each of the six Fund Vehicles for tax years 2022, 2023, and 2024 (or the most recent filed year, as applicable). This request encompasses all K-1s issued to all investors, including the general partner entities, carried interest vehicles, and any co-investment vehicles.

2. To the extent any Schedules K-1 reflect special allocations, curative allocations, or remedial allocations under IRC § 704(c), please identify such items separately and provide the supporting workpapers, allocation models, and any memoranda documenting the methodology applied. We are particularly interested in understanding the interaction between the § 704(c) allocation layers and the book-tax differences reflect

3. In addition to the complete K-1 sets requested above, the Schedules K-1 for the following representative limited partners are of particular interest to our analysis, and we request that any segregated data, supplementary partner-level schedules, or detailed allocation workpapers related to these investors be separately identified and provided: (a) Pinnacle State Employees' Retirement System — Fund IV LP commitment

1. Tax-basis balance sheets (IRS Form 1065, Schedule L, prepared on a tax basis, or equivalent internal workpapers and trial balances) for each of the six Fund Vehicles as of the most recent fiscal year-end (December 31, 2024, or the most recent completed fiscal year) and as of the most recent available interim date (preferably March 31, 2025, or later, if available). To the extent that Caldwell Pierce maintains work

2. For each Fund Vehicle, a detailed reconciliation of GAAP (or IFRS, as applicable) book basis to U.S. federal income tax basis for all material asset categories, including but not limited to: (a) Portfolio company equity interests (both consolidated and unconsolidated); (b) Debt instruments and convertible instruments; (c) Cash and cash equivalents, including amounts held in subscription credit facility reserve acc

3. The Reorganization will involve the transfer of assets from the four offshore Fund Vehicles to the Consolidated Master Fund. The following is our current understanding of the aggregate fair market values, adjusted tax bases, and built-in gains associated with these four vehicles' asset portfolios, and we request that Caldwell Pierce confirm, correct, or supplement these figures based on its records: (a) Fund IV-A

4. Based on the foregoing, our preliminary estimate of the total aggregate fair market value of assets to be transferred to the Consolidated Master Fund is approximately $7.75 billion, with a total adjusted tax basis of approximately $6.03 billion and a total aggregate built-in gain of approximately $1.72 billion. Please confirm whether these aggregate figures are consistent with Caldwell Pierce's records, and provid

1. Complete IRC § 704(c) built-in gain and built-in loss accounts for each item of contributed property held by each of the six Fund Vehicles, current through the most recent allocation period (i.e., the most recent fiscal year-end or, if available, the most recent interim allocation date). These records should include the initial built-in gain or loss at the time of contribution, cumulative allocations made to date,

2. Identification of the allocation method elected under Treas. Reg. § 1.704-3 for each item of contributed property held by each Fund Vehicle. We understand that Solara has generally elected the remedial allocation method under Treas. Reg. § 1.704-3(d) for its contributed properties, but we request confirmation of this understanding on a property-by-property basis. If any properties are subject to the traditional me

3. Detailed § 704(c) schedules for the following representative portfolio company interests, which represent the most significant built-in gain positions across the Fund Vehicles and will be the subject of detailed illustrative examples in the PLR submission: (a) NovaBright Data Systems Inc. — Delaware corporation; data center operator. Fair market value: $890 million; adjusted tax basis: $520 million; built-in gain:

4. Built-in gain/loss tracking records for all remaining portfolio companies held across the Fund Vehicles. We understand that the Fund IV Vehicles hold a total of eleven (11) portfolio company interests and the Fund V Vehicles hold a total of twelve (12) portfolio company interests, for a combined total of twenty-three (23) portfolio company interests across all Fund Vehicles (with the five representative companies

1. Complete schedules of all liabilities — both recourse and nonrecourse — of each of the six Fund Vehicles as of the most recent available date (preferably March 31, 2025, or later). These schedules should include all indebtedness, contingent liabilities, guarantees, indemnification obligations, and any other obligations treated as liabilities for purposes of IRC § 752 and the regulations thereunder.

2. Our preliminary analysis indicates that the aggregate liabilities across the four offshore Fund Vehicles to be assumed by (or allocated to partners of) the Consolidated Master Fund total approximately $1.34 billion. Please confirm this figure and provide a detailed breakdown of these liabilities organized by: (a) Fund Vehicle (i.e., the specific offshore entity to which the liability relates); (b) Liability type,

3. Current partner-level allocations of each liability under Treas. Reg. §§ 1.752-1 through 1.752-5, including: (a) For recourse liabilities: identification of each partner bearing the economic risk of loss within the meaning of Treas. Reg. § 1.752-2, including the amount of economic risk of loss borne by each such partner and the basis for such determination (e.g., guarantee, deficit restoration obligation, or other

4. Information regarding the subscription credit facilities maintained by the Fund IV and Fund V complexes: (a) Fund IV Subscription Credit Facility: $1.1 billion revolving credit facility with Ashford National Bank, N.A. as sole lender. Please provide the current outstanding balance, the borrowing base calculation (including the unfunded capital commitments pledged as collateral), the maturity date, and copies of an

1. Capital account statements, maintained on both a tax basis and a book (GAAP or § 704(b)) basis, for each partner in each of the six Fund Vehicles as of the most recent fiscal year-end (December 31, 2024, or the most recently completed fiscal year) and as of the most recent available interim date (preferably March 31, 2025, or later).

2. Historical capital contribution and distribution records for each Fund Vehicle from inception through the most recent available date. For reference, the inception dates of the Fund Vehicles are as follows: (a) Fund IV LP and Fund IV-A (Cayman) LP: inception June 15, 2021; (b) Fund IV-B (Luxembourg) SCSp: inception June 15, 2021 (or the actual date of formation under Luxembourg law, if different); (c) Fund V LP and

3. Details of any special allocation provisions reflected in capital account maintenance under IRC § 704(b) and the regulations thereunder, including but not limited to: (a) Carried interest allocation provisions (including any catch-up, clawback, or preferred return waterfall provisions); (b) Management fee offset or waiver arrangements; (c) Organizational expense allocations; (d) Any other special allocations requi

1. Copies of any IRS Form 8832 (Entity Classification Election) filed for any of the six Fund Vehicles, the three general partner/management entities, or any predecessor or successor entities, for any period. This includes initial classification elections, changes in classification, and any protective elections. If no Form 8832 was filed for a particular entity because the entity's classification was determined by th

2. Copies of organizational documents for each Fund Vehicle and each general partner/management entity, including: (a) Limited partnership agreements (including all amendments and side letters to the extent they affect tax allocations or entity classification); (b) Partnership agreements or operating agreements; (c) Articles of association, articles of incorporation, or equivalent constitutional documents under Cayma

1. Audited financial statements (prepared in accordance with U.S. GAAP for the Delaware Fund Vehicles or IFRS for the Luxembourg Fund Vehicles, as applicable) for each of the six Fund Vehicles for the three most recent fiscal years (2022, 2023, and 2024, or the most recently completed fiscal year). These should include the balance sheet, statement of operations, statement of changes in partners' capital (or net asset

2. Any management letters, internal control deficiency communications, or other written communications issued by Caldwell Pierce to the management of Solara or any of the Fund Vehicles in connection with the audits described in paragraph 1 above. To the extent that any management letter observations relate to tax reporting, § 704(c) tracking, capital account maintenance, or liability allocations, we request that thos

3. Net asset value ("NAV") reports prepared by Clarendon Fund Services Ltd. (fund administrator; Windward 3, Regatta Office Park, West Bay Road, George Town, Grand Cayman KY1-1108) for the offshore Fund Vehicles (Fund IV-A Cayman, Fund IV-B Luxembourg, Fund V-A Cayman, and Fund V-B Luxembourg), to the extent that Caldwell Pierce has copies of or access to such reports. We are particularly interested in the most recen

1. Copies of all FATCA reporting for the four offshore Fund Vehicles (Fund IV-A Cayman, Fund IV-B Luxembourg, Fund V-A Cayman, and Fund V-B Luxembourg) for the most recent reporting period, including: (a) IRS Form 8966 (FATCA Report) filed with respect to each offshore Fund Vehicle; (b) Any FATCA registration confirmations or Global Intermediary Identification Numbers ("GIINs") assigned to the offshore Fund Vehicles;

2. Common Reporting Standard ("CRS") filings for the Cayman Islands and Luxembourg Fund Vehicles, to the extent maintained by Caldwell Pierce or accessible through Caldwell Pierce's engagement records. We recognize that CRS filings may be prepared by the fund administrator (Clarendon Fund Services Ltd.) or local counsel rather than by Caldwell Pierce, but request that any CRS-related records in Caldwell Pierce's poss

1. Records of any withholding under IRC § 1446 on effectively connected taxable income ("ECTI") allocable to foreign partners of any of the six Fund Vehicles for tax years 2022, 2023, and 2024 (or the most recent filed year). This includes both the § 1446(a) withholding on ECTI allocable to foreign partners and any § 1446(f) withholding on transfers of partnership interests by foreign partners, if applicable.

2. Copies of the following IRS forms filed in connection with § 1446 withholding: (a) IRS Form 8804 (Annual Return for Partnership Withholding Tax — Section 1446); (b) IRS Form 8805 (Foreign Partner's Information Statement of Section 1446 Withholding Tax); and (c) IRS Form 8813 (Partnership Withholding Tax Payment Voucher — Section 1446).

3. Identification of all foreign partners subject to § 1446 withholding, including the applicable withholding rate (21% for corporate foreign partners or 37% for noncorporate foreign partners, or the applicable treaty rate, if any), and the aggregate withholding amounts for each tax year. We note that the following limited partners are of particular relevance given their expected continued investment through the post

1. Any analysis, determination, memorandum, or workpaper previously prepared by Caldwell Pierce (whether in connection with the annual tax compliance process, investor reporting, or otherwise) regarding whether any portfolio company interests held by the Fund Vehicles constitute "United States real property interests" ("USRPIs") within the meaning of IRC § 897(c). This includes any analyses of whether any portfolio c

2. We request particular attention to data center and fiber-optic network assets, where the characterization of underlying tangible assets as real property may be relevant to the FIRPTA analysis. Specifically: (a) NovaBright Data Systems Inc. — As a data center operator, NovaBright may hold significant real property assets (land, buildings, structural improvements) as well as tangible personal property (servers, cool

IV. FORMAT AND DELIVERY INSTRUCTIONS To facilitate efficient review and integration into our working files, we request that all responsive documents and data be provided in accordance with the following format and delivery instructions:

1. File Format: All documents should be provided in electronic format. Tax returns, financial statements, organizational documents, IRS correspondence, and similar narrative or fixed-format documents should be provided in PDF format (searchable/OCR preferred). Schedules, workpapers, tracking records, capital account statements, liability schedules, and other tabular data should be provided in Microsoft Excel format (

2. Delivery Method: All materials should be delivered via Calderwood & Harkness's encrypted file transfer portal. Detailed access instructions, including login credentials and upload procedures, will be provided separately by Robert Jansen under separate cover. Please do not transmit responsive documents via unencrypted email.

3. Organization: Please organize all deliverables by Fund Vehicle (using the six entity names set forth in Section II) and, within each Fund Vehicle folder, by request category (A through K, as set forth in Section III above). A suggested folder structure is as follows: • [Fund Vehicle Name] / A — Tax Returns • [Fund Vehicle Name] / B — Schedules K-1 • [Fund Vehicle Name] / C — Tax-Basis Balance Sheets • [Fund Vehicl

4. Currency Conversion: For any Luxembourg-denominated items, please provide both EUR amounts and USD equivalents using the EUR/USD 1.08 exchange rate, which is the rate consistently applied across all Solara reporting for the current period. If historical periods used a different exchange rate convention, please note the applicable rate and provide a reconciliation.

V. TIMELINE AND PRIORITY The overall timeline for this engagement is driven by the August 15, 2025 target date for submission of the PLR request to the IRS. To meet this deadline, we have established the following internal drafting and review milestones: In light of these milestones, we request the following: Priority Items — Due June 16, 2025: The following categories of data are needed on an expedited basis to supp

VI. COORDINATION WITH REDSTONE ADVISORY GROUP LLC Please be advised that Redstone Advisory Group LLC has been separately engaged by Solara to prepare independent fair market value appraisals of the portfolio company interests being transferred in connection with the Reorganization. The primary contact at Redstone is: Marco DeLuca, Managing Director Redstone Advisory Group LLC 750 Seventh Avenue, 21st Floor New York,

VII. CONFIDENTIALITY AND PRIVILEGE All materials provided by Caldwell Pierce in response to this data request are being furnished in connection with a pending private letter ruling request to the Internal Revenue Service and in furtherance of Calderwood & Harkness's provision of legal advice to Solara Digital Infrastructure LP and its affiliates. Accordingly, all such materials, and all communications between Calderw

VIII. POINTS OF CONTACT For purposes of this data request and the broader PLR engagement, the designated points of contact are as follows: Calderwood & Harkness LLP: Primary Contact: Robert Jansen, Lead Associate, Tax Calderwood & Harkness LLP 1900 K Street NW, Suite 1100 Washington, DC 20006 Direct: (202) 555-7438 Email: rjansen@calderwoodharkness.com Supervising Partner: Leonard Cross, Responsible Partner, Tax Cald