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Form 8832

Entity Classification Election

Department of the Treasury Internal Revenue Service

Under Regulations section 301.7701-3

OMB No. 1545-1516

Completed, ready-to-file version of IRS Form 8832 prepared for Solara International Feeder (Cayman) LP, formatted to mirror the structure and line items of the official IRS form. This document constitutes the entity classification election to be filed with the Internal Revenue Service.

PART I — ELECTION INFORMATION

Line 1 — Check the Applicable box

Type of Election. Check the box that applies to the eligible entity making the election:

(a) A domestic eligible entity electing to be classified as an association taxable as a corporation.

(b) A domestic eligible entity electing to be classified as a partnership.

(d) A foreign eligible entity electing to be classified as an association taxable as a corporation.

(e) A foreign eligible entity electing to be classified as a partnership.

(f) A foreign eligible entity with a single owner electing to be disregarded as a separate entity.

Explanation of Selection. box (e) is checked because Solara International Feeder (Cayman) LP is a foreign eligible entity — specifically, a Cayman Islands exempted limited partnership formed under the Exempted Limited Partnership Act (As Revised) of the Cayman Islands — that elects to be classified as a partnership for United States federal income tax purposes. The entity will have at least two members (one general partner and one or more limited partners) at all times and therefore qualifies for partnership classification. Box (e) is the applicable election under Treas. Reg. § 301.7701-3(a) for a foreign eligible entity with two or more members electing partnership classification.

Line 2 — Information About the Eligible Entity Making the Election

Line 2a — Name of Entity

Solara International Feeder (Cayman) LP

Line 2b — Employer Identification Number (EIN)

Applied For

The entity's Employer Identification Number is to be obtained upon formation. An application for an EIN on IRS Form SS-4 will be filed concurrently with, or immediately prior to, the submission of this Form 8832. The EIN will be inserted into the final executed version of this form upon assignment by the Internal Revenue Service. In the event the EIN is assigned before the filing date of this Form 8832, the assigned number will be entered on this line prior to filing.

Line 2c — Address (Including Suite, Room, or Other Unit Number) and City or Town, State or Province, Country, and ZIP or Foreign Postal Code

Harborstone Corporate Services Ltd. P.O. Box 2714 94 Solaris Avenue George Town, Grand Cayman KY1-1111 Cayman Islands

This is the registered office address of the entity in the Cayman Islands. The same registered office provider, Harborstone Corporate Services Ltd., is utilized by existing Cayman fund vehicles in the Solara platform, including Solara Fund IV-A (Cayman) LP and Solara Fund V-A (Cayman) LP, ensuring administrative consistency across the fund structure.

Line 2d — Country of Organization

Cayman Islands

Line 3 — Type of Entity

Check the applicable box:

A partnership.

The entity will at all times have at least two members, consisting of: (i) the general partner, Solara Offshore GP Ltd. (a Cayman Islands exempted company), or such other entity as may be designated as general partner upon formation; and (ii) at least one limited partner. The anticipated limited partners include non-U.S. institutional investors to be admitted to the entity, including, among others, Nordhaven Sovereign Wealth Fund and Kestrel Pacific Insurance Group, each of which currently invests through the existing Cayman and Luxembourg parallel fund vehicles. These limited partners will migrate into the International Feeder upon dissolution of the legacy offshore vehicles under Step 5 of the reorganization (target effective date December 1, 2025). The entity will therefore have two or more members at all relevant times and is properly classified as a partnership for purposes of this election.

Line 4 — Was the Eligible Entity Previously Classified as Something Other Than What Is Being Elected on Line 1?

No.

This is a newly formed entity. No prior classification exists under the Internal Revenue Code or the Treasury Regulations. Solara International Feeder (Cayman) LP is being formed specifically for the purposes of the cross-border fund-platform reorganization of Solara Digital Infrastructure LP's fund structure. The entity has not previously existed, conducted business, filed a tax return, or been classified for United States federal income tax purposes. Accordingly, there is no change in classification within the meaning of Treas. Reg. § 301.7701-3(c)(1)(iv), and no deemed transaction under Treas. Reg. § 301.7701-3(g) will result from this election.

Line 5 — Election Is To Be Effective Beginning (Month, Day, Year)

September 15, 2025

The requested effective date of September 15, 2025, has been selected to coordinate with the target formation date of the new entities created under Step 1 of the reorganization of Solara Digital Infrastructure LP's fund platform. This effective date ensures that partnership classification for Solara International Feeder (Cayman) LP is in place well in advance of the following critical reorganization milestones:

• Step 2 (target effective date October 1, 2025): The first asset contribution by Solara Fund IV-A (Cayman) LP to Solara Consolidated Master Fund LP, a newly formed Delaware limited partnership. Partnership classification of the International Feeder must be established prior to this date to support the structural integrity of the master-feeder arrangement.

• Step 5 (target effective date December 1, 2025): The dissolution of the legacy offshore parallel fund vehicles (Fund IV-A Cayman, Fund IV-B Lux, Fund V-A Cayman, and Fund V-B Lux) and the migration of non-U.S. investors into the International Feeder. Partnership classification must be operative before non-U.S. investors are admitted as limited partners.

Note Regarding the 75-Day Retroactivity Rule. Under Treas. Reg. § 301.7701-3(c)(1)(iii), an election specifying an effective date may not be filed more than 75 days before the requested effective date, and the election must be filed within 12 months after the requested effective date. For a requested effective date of September 15, 2025, this means that the earliest permissible filing date is July 2, 2025 (75 days before September 15, 2025), and the latest permissible filing date is September 15, 2026. This Form 8832 will be filed on or about September 15, 2025, the formation date of the entity, to ensure full compliance with the timing requirements. Calderwood & Harkness LLP will coordinate the filing to fall within the permissible window.

Line 6 — Entity's Federal Tax Classification Prior to the Election

Not Applicable.

This is a newly formed entity that has had no prior United States federal tax classification. There is no prior classification to report.

For informational purposes, it is noted that under the default classification rules set forth in Treas. Reg. § 301.7701-3(b)(2)(i), a foreign eligible entity with two or more members that does not affirmatively elect a classification is classified as a partnership, provided that at least one member does not have limited liability. In the case of a Cayman Islands exempted limited partnership, the general partner does not have limited liability with respect to the obligations of the partnership (subject to the terms of the limited partnership agreement), and the entity would therefore default to partnership classification in any event. This election is being filed to affirmatively confirm the intended classification and to eliminate any ambiguity regarding the entity's tax status for purposes of the reorganization and the concurrent private letter ruling request.

Line 7 — Was Form 8832 Previously Filed for This Entity?

No.

This is the first filing of Form 8832 for Solara International Feeder (Cayman) LP. The entity is newly formed and has never previously filed an entity classification election with the Internal Revenue Service.

PART II — LATE ELECTION RELIEF

This section is not applicable.

The election reflected in this Form 8832 is being filed on a timely basis, in coordination with the formation of Solara International Feeder (Cayman) LP on the target formation date of September 15, 2025. The filing will be made within the time period prescribed by Treas. Reg. § 301.7701-3(c)(1)(iii) — specifically, no more than 75 days before the requested effective date of September 15, 2025, and no later than 12 months after that date.

Accordingly, no late-election relief is being requested under Revenue Procedure 2009-41, 2009-39 I.R.B. 439, or any successor guidance. The provisions of Part II of Form 8832 relating to reasonable cause for late filing, the representations required to qualify for simplified late-election relief, and the attachment of supporting statements under Revenue Procedure 2009-41 are not completed herein.

PART III — CONSENT STATEMENT AND SIGNATURE(S)

Consent of Each Member

Under the instructions for IRS Form 8832, if an eligible entity has more than one owner, each owner must consent to the entity classification election. The consent of each member may be demonstrated by either: (i) each member signing the Form 8832; or (ii) an authorized person signing the Form 8832 on behalf of the entity, provided that all members have authorized that person to make the election on the entity's behalf. In this case, all members of Solara International Feeder (Cayman) LP, including the general partner and all limited partners who are members as of the effective date, have authorized Viktor Raines, in his capacity as Managing Partner of Solara Digital Infrastructure GP LLC (which serves as the authorized representative of the general partner of Solara International Feeder (Cayman) LP), to execute this Form 8832 on behalf of the entity and all of its members.

Evidence of the authorization of each member is maintained in the files of Calderwood & Harkness LLP, tax counsel to the entity, and will be made available to the Internal Revenue Service upon request.

Statement Under Penalties of Perjury

Under penalties of perjury, I declare that I have examined this election, including any accompanying schedules and statements, and to the best of my knowledge and belief, it is true, correct, and complete. I further declare that I am authorized to make this election on behalf of the above-named entity and all of its members.

Signature: ________

Name: Viktor Raines

Title: Managing Partner, Solara Digital Infrastructure GP LLC (in its capacity as the authorized representative of the general partner of Solara International Feeder (Cayman) LP)

Date: ________

(On or about September 15, 2025)

Contact Person. The following individual is designated as the contact person for purposes of this Form 8832 and may be contacted by the Internal Revenue Service with respect to any questions arising from this election:

Name: Leonard Cross, Responsible Partner, Tax

Firm: Calderwood & Harkness LLP

Address: 1900 K Street NW, Suite 1100, Washington, DC 20006

Telephone: [To be inserted]

An IRS Form 2848 (Power of Attorney and Declaration of Representative) is being filed concurrently with this Form 8832, designating Leonard Cross and Sylvia Hartwell, both of Calderwood & Harkness LLP, as authorized representatives for all Solara entities in connection with the private letter ruling request and all related filings with the Internal Revenue Service. The Form 2848 authorizes these representatives to receive and inspect confidential tax information, to perform any and all acts on behalf of the taxpayer with respect to the entity classification elections and the PLR request, and to execute any documents or agreements that may be required in connection therewith.

ATTACHMENT — SUPPORTING STATEMENT

Filed Pursuant to the Instructions for IRS Form 8832

I. Description of Entity and Purpose of Election

The following information is provided as a supporting statement to the Form 8832 filed on behalf of Solara International Feeder (Cayman) LP:

Purpose of the Entity. Solara International Feeder (Cayman) LP is being formed as a feeder vehicle for non-U.S. investors investing into Solara Consolidated Master Fund LP, a Delaware limited partnership that is also to be formed on September 15, 2025. The International Feeder is a component of a broader cross-border fund-platform reorganization of the fund structure managed and sponsored by Solara Digital Infrastructure LP. The reorganization consolidates four existing offshore parallel fund vehicles — Solara Fund IV-A (Cayman) LP, Solara Fund IV-B (Luxembourg) SCSp, Solara Fund V-A (Cayman) LP, and Solara Fund V-B (Luxembourg) SCSp — into the new Delaware-domiciled Consolidated Master Fund LP, with the International Feeder serving as the vehicle through which non-U.S. investors will invest into the Consolidated Master Fund. The reorganization is structured as a five-step plan and is the subject of a private letter ruling request being submitted by Calderwood & Harkness LLP on behalf of Solara Digital Infrastructure LP.

General Partner. The general partner of Solara International Feeder (Cayman) LP will be Solara Offshore GP Ltd., a Cayman Islands exempted company, or such other entity as may be designated as general partner upon the finalization of the organizational documents. The general partner will have unlimited liability for the obligations of the partnership in accordance with the Exempted Limited Partnership Act and the terms of the limited partnership agreement.

Anticipated Limited Partners. The limited partners of Solara International Feeder (Cayman) LP will consist of non-U.S. investors currently invested in the existing Cayman and Luxembourg parallel fund vehicles. These investors include sovereign wealth funds, non-U.S. insurance companies, and other non-U.S. institutional investors. Specific anticipated investors include Nordhaven Sovereign Wealth Fund and Kestrel Pacific Insurance Group, among others. These limited partners will be admitted to the International Feeder upon the dissolution of the legacy offshore vehicles under Step 5 of the reorganization, which has a target effective date of December 1, 2025. At all times, the entity will have at least two members — one general partner and one or more limited partners — thereby qualifying as a partnership under the Treasury Regulations.

Number of Members/Partners. Solara International Feeder (Cayman) LP will have at least two members at all times, consisting of the general partner and one or more limited partners. This structural requirement satisfies the conditions for partnership classification under Treas. Reg. § 301.7701-3(a) and precludes classification as a disregarded entity.

II. Relationship to Other Entity Classification Elections Filed Concurrently

This Form 8832 is being filed concurrently with the following additional entity classification elections, each of which shares the same requested effective date of September 15, 2025:

1. Form 8832 for Solara Consolidated Master Fund LP — A newly formed Delaware limited partnership electing to be classified as a partnership for United States federal income tax purposes. The Consolidated Master Fund LP serves as the central investment vehicle in the reorganized fund structure and will receive the assets and liabilities of the four legacy offshore parallel fund vehicles.

2. Form 8832 for Solara Tax-Exempt Feeder (Cayman) LP — A newly formed Cayman Islands exempted limited partnership electing to be classified as a partnership for United States federal income tax purposes. The Tax-Exempt Feeder serves as the vehicle through which U.S. tax-exempt investors (including pension funds, endowments, and foundations) will invest into the Consolidated Master Fund LP, providing a structure designed to minimize unrelated business taxable income (UBTI) for such investors.

All three entity classification elections are coordinated under Step 1 of the five-step reorganization plan. The uniform effective date of September 15, 2025, ensures that the new fund platform entities are classified as partnerships from inception, thereby providing certainty as to the tax treatment of subsequent transactions under Steps 2 through 5 of the reorganization.

These elections are an integral component of the private letter ruling request (PLR) being submitted to the Internal Revenue Service, Office of the Associate Chief Counsel (International) (CC:INTL), with secondary jurisdiction in CC:PSI (Passthroughs & Special Industries), by Calderwood & Harkness LLP on behalf of Solara Digital Infrastructure LP. The PLR request bears engagement number 20250527-SDILP-PLR, and the target submission date for the ruling request is August 15, 2025.

III. Confirmation of Eligible Entity Status

Solara International Feeder (Cayman) LP is an "eligible entity" within the meaning of Treas. Reg. § 301.7701-3(a). An eligible entity is a business entity that is not classified as a corporation under Treas. Reg. § 301.7701-2(b)(1), (3), (4), (5), (6), (7), or (8). In particular, Treas. Reg. § 301.7701-2(b)(8) sets forth a list of certain foreign business entities that are treated as per se corporations for United States federal income tax purposes (commonly referred to as the "per se corporation list").

A Cayman Islands exempted limited partnership is not included among the entities listed in Treas. Reg. § 301.7701-2(b)(8)(i). The per se corporation list for the Cayman Islands does not include limited partnerships formed under the Exempted Limited Partnership Act (As Revised). Only certain specified entities organized under the laws of particular foreign jurisdictions are classified as per se corporations, and a Cayman Islands exempted limited partnership is not among them.

Because Solara International Feeder (Cayman) LP is a business entity that is not a per se corporation under Treas. Reg. § 301.7701-2(b)(8), it qualifies as an eligible entity under Treas. Reg. § 301.7701-3(a) and may affirmatively elect its classification for United States federal income tax purposes. The entity elects to be classified as a partnership under Treas. Reg. § 301.7701-3(c), as reflected in Part I, Line 1(e) of this Form 8832.

A detailed analysis confirming the eligible-entity status of Solara International Feeder (Cayman) LP and all other newly formed entities in the reorganized fund structure is set forth in the Tax Memorandum — Entity Classification Under Treas. Reg. § 301.7701-3 prepared by Calderwood & Harkness LLP, which is maintained in the firm's files and is available for submission to the Internal Revenue Service in connection with the PLR request upon request.

FILING INSTRUCTIONS AND MAILING ADDRESS

Where to File

This Form 8832 is to be filed by mailing the completed and executed original to the following address:

Internal Revenue Service Ogden, UT 84201

This is the designated filing address per the current instructions for Form 8832 for foreign entities that do not have a principal office or place of business in the United States. Because Solara International Feeder (Cayman) LP is organized in the Cayman Islands and maintains its registered office in George Town, Grand Cayman, the Ogden address is the correct mailing address for filing purposes.

Copies. A copy of this Form 8832 must be attached to the entity's United States federal income tax return (Form 1065, U.S. Return of Partnership Income) for the tax year in which the election takes effect. Because the election is effective September 15, 2025, the entity's first taxable year as a partnership will commence on that date, and the Form 1065 for the short taxable year ending December 31, 2025, should include a copy of this election as an attachment.

Timing of Filing

Under Treas. Reg. § 301.7701-3(c)(1)(iii), the election may be filed no more than 75 days before the requested effective date, and no later than 12 months after the requested effective date. For the requested effective date of September 15, 2025:

• Earliest permissible filing date: July 2, 2025 (75 days before September 15, 2025)

• Latest permissible filing date: September 15, 2026 (12 months after September 15, 2025)

This Form 8832 will be filed on or about September 15, 2025, the date of formation of the entity, to ensure compliance with the timing requirements and to establish the classification of the entity from the date of its formation.

Coordination of Filing

The filing of this Form 8832 will be coordinated by Calderwood & Harkness LLP, tax counsel to the entity, and specifically by the following attorneys:

• Robert Jansen, Lead Associate, Tax (Washington, D.C. office)

• Garrett Simmons, Working Associate, Tax (New York office)

These attorneys are responsible for the preparation, review, and submission of this Form 8832 as part of the broader reorganization filing package, which includes the concurrent Form 8832 elections for Solara Consolidated Master Fund LP and Solara Tax-Exempt Feeder (Cayman) LP, as well as the private letter ruling request and all supporting memoranda and exhibits.

INTERNAL CALDERWOOD & HARKNESS COVER NOTES

THIS PAGE IS NOT PART OF THE IRS FILING AND IS FOR INTERNAL USE ONLY

PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT

Cross-References to Related Work Product

Memorandum on Timing of Check-the-box Elections. This Form 8832 should be read in conjunction with the Memorandum on Timing of Check-the-box Elections prepared by Calderwood & Harkness LLP, which provides a comprehensive analysis of: (i) the effective-date coordination of the three concurrent entity classification elections with the five steps of the reorganization; (ii) the application of the 75-day retroactivity rule under Treas. Reg. § 301.7701-3(c)(1)(iii) to each election; (iii) the consequences of potential delays in formation or filing; and (iv) the availability of late-election relief under Revenue Procedure 2009-41 in the event that any election is not timely filed. The memorandum concludes that the target filing date of September 15, 2025, for all three elections falls within the permissible filing window and that no late-election relief should be necessary absent unanticipated delays.

Tax Memorandum — Entity Classification Under Treas. Reg. § 301.7701-3. This Form 8832 should also be read in conjunction with the Tax Memorandum — Entity Classification Under Treas. Reg. § 301.7701-3, which provides a full analysis confirming the eligible-entity status of Solara International Feeder (Cayman) LP and all other newly formed entities in the reorganized fund structure. The memorandum addresses: (i) the per se corporation list under Treas. Reg. § 301.7701-2(b)(8) and the exclusion of Cayman Islands exempted limited partnerships from that list; (ii) the default classification rules under Treas. Reg. § 301.7701-3(b)(2) applicable to foreign eligible entities; (iii) the limited-liability analysis for the general partner under the Exempted Limited Partnership Act (As Revised); and (iv) the effect of the entity classification elections on the broader reorganization, including the treatment of asset contributions, deemed exchanges, and the dissolution of legacy vehicles.

Filing Checklist.

Confirm EIN assignment via Form SS-4 and insert EIN on Line 2b prior to filing.

Obtain executed signature page from Viktor Raines.

Confirm that all members have authorized Viktor Raines to execute the election on behalf of the entity and maintain evidence of authorization in engagement files.

File concurrent Form 2848 (Power of Attorney) designating Leonard Cross and Sylvia Hartwell as authorized representatives.

Coordinate filing with concurrent Form 8832 elections for Solara Consolidated Master Fund LP and Solara Tax-Exempt Feeder (Cayman) LP.

Mail executed original to IRS, Ogden, UT 84201.

Retain copy for engagement files and for attachment to entity's first Form 1065.

Calendar latest permissible filing date (September 15, 2026) as a backstop deadline.

Confirm CIMA registration application has been submitted by Meridian Offshore Legal.

END OF DOCUMENT

Item	Detail
Entity Name	Solara International Feeder (Cayman) LP
Entity Type	Cayman Islands exempted limited partnership
Governing Law	Exempted Limited Partnership Act (As Revised) of the Cayman Islands
Date of Formation	Target September 15, 2025
Jurisdiction of Formation	Cayman Islands
Registered Office	Harborstone Corporate Services Ltd., P.O. Box 2714, 94 Solaris Avenue, George Town, Grand Cayman KY1-1111
Cayman Islands Counsel	Meridian Offshore Legal (Fiona McAllister, Partner), Caledonia House, 69 Dr. Roy's Drive, George Town, Grand Cayman KY1-1103
CIMA Registration	To be applied for upon formation with the Cayman Islands Monetary Authority
Item	Detail
Matter Reference	Engagement No. 20250527-SDILP-PLR
Client	Solara Digital Infrastructure LP
Form	IRS Form 8832 — Entity Classification Election
Entity	Solara International Feeder (Cayman) LP
Prepared By	Garrett Simmons, Working Associate, Tax (New York office)
Reviewed By	Robert Jansen, Lead Associate, Tax (D.C. office)
Approved By	Leonard Cross, Responsible Partner, Tax (D.C. office)
Date of Preparation	[Date]
Status	Draft — Pending Final Execution and Filing

Form 8832
Entity Classification Election
Department of the Treasury Internal Revenue Service
Under Regulations section 301.7701-3
OMB No. 1545-1516
Completed, ready-to-file version of IRS Form 8832 prepared for Solara International Feeder (Cayman) LP, formatted to mirror the structure and line items of the official IRS form. This document constitutes the entity classification election to be filed with the Internal Revenue Service.
PART I — ELECTION INFORMATION
Line 1 — Check the Applicable box
Type of Election. Check the box that applies to the eligible entity making the election:
(a) A domestic eligible entity electing to be classified as an association taxable as a corporation.
(b) A domestic eligible entity electing to be classified as a partnership.
(c) A domestic eligible entity with a single owner electing to be disregarded as a separate entity.
(d) A foreign eligible entity electing to be classified as an association taxable as a corporation.
(e) A foreign eligible entity electing to be classified as a partnership.
(f) A foreign eligible entity with a single owner electing to be disregarded as a separate entity.
Explanation of Selection. box (e) is checked because Solara International Feeder (Cayman) LP is a foreign eligible entity — specifically, a Cayman Islands exempted limited partnership formed under the Exempted Limited Partnership Act (As Revised) of the Cayman Islands — that elects to be classified as a partnership for United States federal income tax purposes. The entity will have at least two members (one general partner and one or more limited partners) at all times and therefore qualifies for partnership classification. Box (e) is the applicable election under Treas. Reg. § 301.7701-3(a) for a foreign eligible entity with two or more members electing partnership classification.
Line 2 — Information About the Eligible Entity Making the Election
Line 2a — Name of Entity
Solara International Feeder (Cayman) LP
Line 2b — Employer Identification Number (EIN)
Applied For
The entity's Employer Identification Number is to be obtained upon formation. An application for an EIN on IRS Form SS-4 will be filed concurrently with, or immediately prior to, the submission of this Form 8832. The EIN will be inserted into the final executed version of this form upon assignment by the Internal Revenue Service. In the event the EIN is assigned before the filing date of this Form 8832, the assigned number will be entered on this line prior to filing.
Line 2c — Address (Including Suite, Room, or Other Unit Number) and City or Town, State or Province, Country, and ZIP or Foreign Postal Code
Harborstone Corporate Services Ltd. P.O. Box 2714 94 Solaris Avenue George Town, Grand Cayman KY1-1111 Cayman Islands
This is the registered office address of the entity in the Cayman Islands. The same registered office provider, Harborstone Corporate Services Ltd., is utilized by existing Cayman fund vehicles in the Solara platform, including Solara Fund IV-A (Cayman) LP and Solara Fund V-A (Cayman) LP, ensuring administrative consistency across the fund structure.
Line 2d — Country of Organization
Cayman Islands
Line 3 — Type of Entity
Check the applicable box:
A partnership.
The entity will at all times have at least two members, consisting of: (i) the general partner, Solara Offshore GP Ltd. (a Cayman Islands exempted company), or such other entity as may be designated as general partner upon formation; and (ii) at least one limited partner. The anticipated limited partners include non-U.S. institutional investors to be admitted to the entity, including, among others, Nordhaven Sovereign Wealth Fund and Kestrel Pacific Insurance Group, each of which currently invests through the existing Cayman and Luxembourg parallel fund vehicles. These limited partners will migrate into the International Feeder upon dissolution of the legacy offshore vehicles under Step 5 of the reorganization (target effective date December 1, 2025). The entity will therefore have two or more members at all relevant times and is properly classified as a partnership for purposes of this election.
Line 4 — Was the Eligible Entity Previously Classified as Something Other Than What Is Being Elected on Line 1?
No.
This is a newly formed entity. No prior classification exists under the Internal Revenue Code or the Treasury Regulations. Solara International Feeder (Cayman) LP is being formed specifically for the purposes of the cross-border fund-platform reorganization of Solara Digital Infrastructure LP's fund structure. The entity has not previously existed, conducted business, filed a tax return, or been classified for United States federal income tax purposes. Accordingly, there is no change in classification within the meaning of Treas. Reg. § 301.7701-3(c)(1)(iv), and no deemed transaction under Treas. Reg. § 301.7701-3(g) will result from this election.
Line 5 — Election Is To Be Effective Beginning (Month, Day, Year)
September 15, 2025
The requested effective date of September 15, 2025, has been selected to coordinate with the target formation date of the new entities created under Step 1 of the reorganization of Solara Digital Infrastructure LP's fund platform. This effective date ensures that partnership classification for Solara International Feeder (Cayman) LP is in place well in advance of the following critical reorganization milestones:
•  Step 2 (target effective date October 1, 2025): The first asset contribution by Solara Fund IV-A (Cayman) LP to Solara Consolidated Master Fund LP, a newly formed Delaware limited partnership. Partnership classification of the International Feeder must be established prior to this date to support the structural integrity of the master-feeder arrangement.
•  Step 5 (target effective date December 1, 2025): The dissolution of the legacy offshore parallel fund vehicles (Fund IV-A Cayman, Fund IV-B Lux, Fund V-A Cayman, and Fund V-B Lux) and the migration of non-U.S. investors into the International Feeder. Partnership classification must be operative before non-U.S. investors are admitted as limited partners.
Note Regarding the 75-Day Retroactivity Rule. Under Treas. Reg. § 301.7701-3(c)(1)(iii), an election specifying an effective date may not be filed more than 75 days before the requested effective date, and the election must be filed within 12 months after the requested effective date. For a requested effective date of September 15, 2025, this means that the earliest permissible filing date is July 2, 2025 (75 days before September 15, 2025), and the latest permissible filing date is September 15, 2026. This Form 8832 will be filed on or about September 15, 2025, the formation date of the entity, to ensure full compliance with the timing requirements. Calderwood & Harkness LLP will coordinate the filing to fall within the permissible window.
Line 6 — Entity's Federal Tax Classification Prior to the Election
Not Applicable.
This is a newly formed entity that has had no prior United States federal tax classification. There is no prior classification to report.
For informational purposes, it is noted that under the default classification rules set forth in Treas. Reg. § 301.7701-3(b)(2)(i), a foreign eligible entity with two or more members that does not affirmatively elect a classification is classified as a partnership, provided that at least one member does not have limited liability. In the case of a Cayman Islands exempted limited partnership, the general partner does not have limited liability with respect to the obligations of the partnership (subject to the terms of the limited partnership agreement), and the entity would therefore default to partnership classification in any event. This election is being filed to affirmatively confirm the intended classification and to eliminate any ambiguity regarding the entity's tax status for purposes of the reorganization and the concurrent private letter ruling request.
Line 7 — Was Form 8832 Previously Filed for This Entity?
No.
This is the first filing of Form 8832 for Solara International Feeder (Cayman) LP. The entity is newly formed and has never previously filed an entity classification election with the Internal Revenue Service.
PART II — LATE ELECTION RELIEF
This section is not applicable.
The election reflected in this Form 8832 is being filed on a timely basis, in coordination with the formation of Solara International Feeder (Cayman) LP on the target formation date of September 15, 2025. The filing will be made within the time period prescribed by Treas. Reg. § 301.7701-3(c)(1)(iii) — specifically, no more than 75 days before the requested effective date of September 15, 2025, and no later than 12 months after that date.
Accordingly, no late-election relief is being requested under Revenue Procedure 2009-41, 2009-39 I.R.B. 439, or any successor guidance. The provisions of Part II of Form 8832 relating to reasonable cause for late filing, the representations required to qualify for simplified late-election relief, and the attachment of supporting statements under Revenue Procedure 2009-41 are not completed herein.
PART III — CONSENT STATEMENT AND SIGNATURE(S)
Consent of Each Member
Under the instructions for IRS Form 8832, if an eligible entity has more than one owner, each owner must consent to the entity classification election. The consent of each member may be demonstrated by either: (i) each member signing the Form 8832; or (ii) an authorized person signing the Form 8832 on behalf of the entity, provided that all members have authorized that person to make the election on the entity's behalf. In this case, all members of Solara International Feeder (Cayman) LP, including the general partner and all limited partners who are members as of the effective date, have authorized Viktor Raines, in his capacity as Managing Partner of Solara Digital Infrastructure GP LLC (which serves as the authorized representative of the general partner of Solara International Feeder (Cayman) LP), to execute this Form 8832 on behalf of the entity and all of its members.
Evidence of the authorization of each member is maintained in the files of Calderwood & Harkness LLP, tax counsel to the entity, and will be made available to the Internal Revenue Service upon request.
Statement Under Penalties of Perjury
Under penalties of perjury, I declare that I have examined this election, including any accompanying schedules and statements, and to the best of my knowledge and belief, it is true, correct, and complete. I further declare that I am authorized to make this election on behalf of the above-named entity and all of its members.
Signature: ________
Name: Viktor Raines
Title: Managing Partner, Solara Digital Infrastructure GP LLC (in its capacity as the authorized representative of the general partner of Solara International Feeder (Cayman) LP)
Date: ________
(On or about September 15, 2025)
Contact Person.  The following individual is designated as the contact person for purposes of this Form 8832 and may be contacted by the Internal Revenue Service with respect to any questions arising from this election:
Name: Leonard Cross, Responsible Partner, Tax
Firm: Calderwood & Harkness LLP
Address: 1900 K Street NW, Suite 1100, Washington, DC 20006
Telephone: [To be inserted]
An IRS Form 2848 (Power of Attorney and Declaration of Representative) is being filed concurrently with this Form 8832, designating Leonard Cross and Sylvia Hartwell, both of Calderwood & Harkness LLP, as authorized representatives for all Solara entities in connection with the private letter ruling request and all related filings with the Internal Revenue Service. The Form 2848 authorizes these representatives to receive and inspect confidential tax information, to perform any and all acts on behalf of the taxpayer with respect to the entity classification elections and the PLR request, and to execute any documents or agreements that may be required in connection therewith.
ATTACHMENT — SUPPORTING STATEMENT
Filed Pursuant to the Instructions for IRS Form 8832
I. Description of Entity and Purpose of Election
The following information is provided as a supporting statement to the Form 8832 filed on behalf of Solara International Feeder (Cayman) LP:
Purpose of the Entity. Solara International Feeder (Cayman) LP is being formed as a feeder vehicle for non-U.S. investors investing into Solara Consolidated Master Fund LP, a Delaware limited partnership that is also to be formed on September 15, 2025. The International Feeder is a component of a broader cross-border fund-platform reorganization of the fund structure managed and sponsored by Solara Digital Infrastructure LP. The reorganization consolidates four existing offshore parallel fund vehicles — Solara Fund IV-A (Cayman) LP, Solara Fund IV-B (Luxembourg) SCSp, Solara Fund V-A (Cayman) LP, and Solara Fund V-B (Luxembourg) SCSp — into the new Delaware-domiciled Consolidated Master Fund LP, with the International Feeder serving as the vehicle through which non-U.S. investors will invest into the Consolidated Master Fund. The reorganization is structured as a five-step plan and is the subject of a private letter ruling request being submitted by Calderwood & Harkness LLP on behalf of Solara Digital Infrastructure LP.
General Partner. The general partner of Solara International Feeder (Cayman) LP will be Solara Offshore GP Ltd., a Cayman Islands exempted company, or such other entity as may be designated as general partner upon the finalization of the organizational documents. The general partner will have unlimited liability for the obligations of the partnership in accordance with the Exempted Limited Partnership Act and the terms of the limited partnership agreement.
Anticipated Limited Partners. The limited partners of Solara International Feeder (Cayman) LP will consist of non-U.S. investors currently invested in the existing Cayman and Luxembourg parallel fund vehicles. These investors include sovereign wealth funds, non-U.S. insurance companies, and other non-U.S. institutional investors. Specific anticipated investors include Nordhaven Sovereign Wealth Fund and Kestrel Pacific Insurance Group, among others. These limited partners will be admitted to the International Feeder upon the dissolution of the legacy offshore vehicles under Step 5 of the reorganization, which has a target effective date of December 1, 2025. At all times, the entity will have at least two members — one general partner and one or more limited partners — thereby qualifying as a partnership under the Treasury Regulations.
Number of Members/Partners. Solara International Feeder (Cayman) LP will have at least two members at all times, consisting of the general partner and one or more limited partners. This structural requirement satisfies the conditions for partnership classification under Treas. Reg. § 301.7701-3(a) and precludes classification as a disregarded entity.
II. Relationship to Other Entity Classification Elections Filed Concurrently
This Form 8832 is being filed concurrently with the following additional entity classification elections, each of which shares the same requested effective date of September 15, 2025:
1.  Form 8832 for Solara Consolidated Master Fund LP — A newly formed Delaware limited partnership electing to be classified as a partnership for United States federal income tax purposes. The Consolidated Master Fund LP serves as the central investment vehicle in the reorganized fund structure and will receive the assets and liabilities of the four legacy offshore parallel fund vehicles.
2.  Form 8832 for Solara Tax-Exempt Feeder (Cayman) LP — A newly formed Cayman Islands exempted limited partnership electing to be classified as a partnership for United States federal income tax purposes. The Tax-Exempt Feeder serves as the vehicle through which U.S. tax-exempt investors (including pension funds, endowments, and foundations) will invest into the Consolidated Master Fund LP, providing a structure designed to minimize unrelated business taxable income (UBTI) for such investors.
All three entity classification elections are coordinated under Step 1 of the five-step reorganization plan. The uniform effective date of September 15, 2025, ensures that the new fund platform entities are classified as partnerships from inception, thereby providing certainty as to the tax treatment of subsequent transactions under Steps 2 through 5 of the reorganization.
These elections are an integral component of the private letter ruling request (PLR) being submitted to the Internal Revenue Service, Office of the Associate Chief Counsel (International) (CC:INTL), with secondary jurisdiction in CC:PSI (Passthroughs & Special Industries), by Calderwood & Harkness LLP on behalf of Solara Digital Infrastructure LP. The PLR request bears engagement number 20250527-SDILP-PLR, and the target submission date for the ruling request is August 15, 2025.
III. Confirmation of Eligible Entity Status
Solara International Feeder (Cayman) LP is an "eligible entity" within the meaning of Treas. Reg. § 301.7701-3(a). An eligible entity is a business entity that is not classified as a corporation under Treas. Reg. § 301.7701-2(b)(1), (3), (4), (5), (6), (7), or (8). In particular, Treas. Reg. § 301.7701-2(b)(8) sets forth a list of certain foreign business entities that are treated as per se corporations for United States federal income tax purposes (commonly referred to as the "per se corporation list").
A Cayman Islands exempted limited partnership is not included among the entities listed in Treas. Reg. § 301.7701-2(b)(8)(i). The per se corporation list for the Cayman Islands does not include limited partnerships formed under the Exempted Limited Partnership Act (As Revised). Only certain specified entities organized under the laws of particular foreign jurisdictions are classified as per se corporations, and a Cayman Islands exempted limited partnership is not among them.
Because Solara International Feeder (Cayman) LP is a business entity that is not a per se corporation under Treas. Reg. § 301.7701-2(b)(8), it qualifies as an eligible entity under Treas. Reg. § 301.7701-3(a) and may affirmatively elect its classification for United States federal income tax purposes. The entity elects to be classified as a partnership under Treas. Reg. § 301.7701-3(c), as reflected in Part I, Line 1(e) of this Form 8832.
A detailed analysis confirming the eligible-entity status of Solara International Feeder (Cayman) LP and all other newly formed entities in the reorganized fund structure is set forth in the Tax Memorandum — Entity Classification Under Treas. Reg. § 301.7701-3 prepared by Calderwood & Harkness LLP, which is maintained in the firm's files and is available for submission to the Internal Revenue Service in connection with the PLR request upon request.
FILING INSTRUCTIONS AND MAILING ADDRESS
Where to File
This Form 8832 is to be filed by mailing the completed and executed original to the following address:
Internal Revenue Service Ogden, UT 84201
This is the designated filing address per the current instructions for Form 8832 for foreign entities that do not have a principal office or place of business in the United States. Because Solara International Feeder (Cayman) LP is organized in the Cayman Islands and maintains its registered office in George Town, Grand Cayman, the Ogden address is the correct mailing address for filing purposes.
Copies.  A copy of this Form 8832 must be attached to the entity's United States federal income tax return (Form 1065, U.S. Return of Partnership Income) for the tax year in which the election takes effect. Because the election is effective September 15, 2025, the entity's first taxable year as a partnership will commence on that date, and the Form 1065 for the short taxable year ending December 31, 2025, should include a copy of this election as an attachment.
Timing of Filing
Under Treas. Reg. § 301.7701-3(c)(1)(iii), the election may be filed no more than 75 days before the requested effective date, and no later than 12 months after the requested effective date. For the requested effective date of September 15, 2025:
•  Earliest permissible filing date: July 2, 2025 (75 days before September 15, 2025)
•  Latest permissible filing date: September 15, 2026 (12 months after September 15, 2025)
This Form 8832 will be filed on or about September 15, 2025, the date of formation of the entity, to ensure compliance with the timing requirements and to establish the classification of the entity from the date of its formation.
Coordination of Filing
The filing of this Form 8832 will be coordinated by Calderwood & Harkness LLP, tax counsel to the entity, and specifically by the following attorneys:
•  Robert Jansen, Lead Associate, Tax (Washington, D.C. office)
•  Garrett Simmons, Working Associate, Tax (New York office)
These attorneys are responsible for the preparation, review, and submission of this Form 8832 as part of the broader reorganization filing package, which includes the concurrent Form 8832 elections for Solara Consolidated Master Fund LP and Solara Tax-Exempt Feeder (Cayman) LP, as well as the private letter ruling request and all supporting memoranda and exhibits.
INTERNAL CALDERWOOD & HARKNESS COVER NOTES
THIS PAGE IS NOT PART OF THE IRS FILING AND IS FOR INTERNAL USE ONLY
PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT
Cross-References to Related Work Product
Memorandum on Timing of Check-the-box Elections. This Form 8832 should be read in conjunction with the Memorandum on Timing of Check-the-box Elections prepared by Calderwood & Harkness LLP, which provides a comprehensive analysis of: (i) the effective-date coordination of the three concurrent entity classification elections with the five steps of the reorganization; (ii) the application of the 75-day retroactivity rule under Treas. Reg. § 301.7701-3(c)(1)(iii) to each election; (iii) the consequences of potential delays in formation or filing; and (iv) the availability of late-election relief under Revenue Procedure 2009-41 in the event that any election is not timely filed. The memorandum concludes that the target filing date of September 15, 2025, for all three elections falls within the permissible filing window and that no late-election relief should be necessary absent unanticipated delays.
Tax Memorandum — Entity Classification Under Treas. Reg. § 301.7701-3. This Form 8832 should also be read in conjunction with the Tax Memorandum — Entity Classification Under Treas. Reg. § 301.7701-3, which provides a full analysis confirming the eligible-entity status of Solara International Feeder (Cayman) LP and all other newly formed entities in the reorganized fund structure. The memorandum addresses: (i) the per se corporation list under Treas. Reg. § 301.7701-2(b)(8) and the exclusion of Cayman Islands exempted limited partnerships from that list; (ii) the default classification rules under Treas. Reg. § 301.7701-3(b)(2) applicable to foreign eligible entities; (iii) the limited-liability analysis for the general partner under the Exempted Limited Partnership Act (As Revised); and (iv) the effect of the entity classification elections on the broader reorganization, including the treatment of asset contributions, deemed exchanges, and the dissolution of legacy vehicles.
Filing Checklist.  
Confirm EIN assignment via Form SS-4 and insert EIN on Line 2b prior to filing.
Obtain executed signature page from Viktor Raines.
Confirm that all members have authorized Viktor Raines to execute the election on behalf of the entity and maintain evidence of authorization in engagement files.
File concurrent Form 2848 (Power of Attorney) designating Leonard Cross and Sylvia Hartwell as authorized representatives.
Coordinate filing with concurrent Form 8832 elections for Solara Consolidated Master Fund LP and Solara Tax-Exempt Feeder (Cayman) LP.
Mail executed original to IRS, Ogden, UT 84201.
Retain copy for engagement files and for attachment to entity's first Form 1065.
Calendar latest permissible filing date (September 15, 2026) as a backstop deadline.
Confirm CIMA registration application has been submitted by Meridian Offshore Legal.
END OF DOCUMENT
Item | Detail
Entity Name | Solara International Feeder (Cayman) LP
Entity Type | Cayman Islands exempted limited partnership
Governing Law | Exempted Limited Partnership Act (As Revised) of the Cayman Islands
Date of Formation | Target September 15, 2025
Jurisdiction of Formation | Cayman Islands
Registered Office | Harborstone Corporate Services Ltd., P.O. Box 2714, 94 Solaris Avenue, George Town, Grand Cayman KY1-1111
Cayman Islands Counsel | Meridian Offshore Legal (Fiona McAllister, Partner), Caledonia House, 69 Dr. Roy's Drive, George Town, Grand Cayman KY1-1103
CIMA Registration | To be applied for upon formation with the Cayman Islands Monetary Authority
Item | Detail
Matter Reference | Engagement No. 20250527-SDILP-PLR
Client | Solara Digital Infrastructure LP
Form | IRS Form 8832 — Entity Classification Election
Entity | Solara International Feeder (Cayman) LP
Prepared By | Garrett Simmons, Working Associate, Tax (New York office)
Reviewed By | Robert Jansen, Lead Associate, Tax (D.C. office)
Approved By | Leonard Cross, Responsible Partner, Tax (D.C. office)
Date of Preparation | [Date]
Status | Draft — Pending Final Execution and Filing

Form 8832

FILING INSTRUCTIONS AND MAILING ADDRESS

INTERNAL CALDERWOOD & HARKNESS COVER NOTES

THIS PAGE IS NOT PART OF THE IRS FILING AND IS FOR INTERNAL USE ONLY

END OF DOCUMENT

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