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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

NOTE: This document is a completed Form 8832 reflecting all entries as they would appear on the official IRS Form 8832 (Rev. January 2012). This draft has been prepared by Calderwood & Harkness LLP for review and execution by the authorized representatives of Solara Consolidated Master Fund LP. All entries correspond to the applicable lines and checkboxes on the official printed form. Upon finalization, this information will be transcribed onto the official IRS form for filing, or this document may be submitted in lieu thereof to the extent permitted by applicable IRS instructions and guidance. References to "check box" or "checked" below indicate the selection that will be marked on the official form.

PART I — ELECTION INFORMATION

Line 1 — Type of Election

Check the box that applies:

• [X] Initial classification by a newly formed entity

• [ ] Change in current classification

• [ ] Late election relief under Revenue Procedure 2009-41 or successor guidance

Explanation: Solara Consolidated Master Fund LP is a newly formed Delaware limited partnership. The entity does not currently exist and is expected to be formed on September 15, 2025, by the filing of a Certificate of Limited Partnership with the Delaware Secretary of State. This election constitutes an initial classification election under Treasury Regulations section 301.7701-3(c), and is not a change in classification of an existing entity. Because the entity is newly formed, no prior classification exists, and this election is being submitted to affirmatively establish the entity's classification for U.S. federal income tax purposes from the date of its formation.

Line 2 — Form of Entity Eligible to Make Election

Check the box that applies:

• [X] A domestic eligible entity electing to be classified as a partnership

• [ ] A domestic eligible entity electing to be classified as an association taxable as a corporation

• [ ] A domestic eligible entity with a single owner electing to be disregarded as a separate entity

• [ ] A foreign eligible entity electing to be classified as a partnership

• [ ] A foreign eligible entity electing to be classified as an association taxable as a corporation

• [ ] A foreign eligible entity with a single owner electing to be disregarded as a separate entity

Explanation: Solara Consolidated Master Fund LP is a domestic eligible entity (formed under the laws of the State of Delaware) with more than one member (a general partner and multiple limited partners). The entity is electing to be classified as a partnership for U.S. federal income tax purposes. A domestic limited partnership with two or more members is an "eligible entity" within the meaning of Treasury Regulations section 301.7701-3(a), as it is a business entity that is not classified as a corporation under Treasury Regulations section 301.7701-2(b) (i.e., it is not a per se corporation). While partnership classification would also be the default classification for a domestic eligible entity with two or more members under Treasury Regulations section 301.7701-3(b)(1), this affirmative election is being made to confirm and lock in such classification in connection with a multi-step reorganization transaction involving the contribution of assets with a total fair market value of approximately $7.75 billion.

Line 3 — Disregarded Entity Information

Not applicable. This line is left blank. Solara Consolidated Master Fund LP will have more than one member (owner) as of its formation date and is not electing to be classified as a disregarded entity. The entity will have both a general partner (Solara Consolidated Master Fund GP LLC) and multiple limited partners, as described further in the Consent Statement section below and in the attached Supplemental Information addendum.

Line 4 — Name and Employer Identification Number (EIN) of Eligible Entity Making Election

Name of Eligible Entity:

Solara Consolidated Master Fund LP

Employer Identification Number (EIN):

Applied For

(Application for EIN is pending. Form SS-4, Application for Employer Identification Number, will be filed with the Internal Revenue Service in connection with the formation of the entity on or about September 15, 2025. If the EIN has been assigned prior to the filing date of this Form 8832, the assigned EIN will be inserted on the official filed version of this form. If the EIN has not yet been received, this form will be filed with the notation "Applied For" in the EIN field, consistent with the instructions to Form 8832.)

Line 5 — Address of Eligible Entity

This is the headquarters address of Solara Digital Infrastructure LP, the fund platform sponsor, which will serve as the principal office of Solara Consolidated Master Fund LP. All correspondence from the Internal Revenue Service regarding this Form 8832 election should be directed to this address unless an authorized representative has been designated on a valid Form 2848, Power of Attorney and Declaration of Representative (see Line 11 below for additional authorized representative addresses).

Line 6 — Type of Entity

Check the box that applies:

• [X] A domestic entity (formed or organized in the United States or under the law of the United States or of any State)

• [ ] A foreign entity (formed or organized under the law of a foreign country)

Explanation: Solara Consolidated Master Fund LP is a domestic entity. It will be formed as a limited partnership under the Delaware Revised Uniform Limited Partnership Act, 6 Del. C. § 17-101 et seq., by the filing of a Certificate of Limited Partnership with the Secretary of State of the State of Delaware. Delaware is a State of the United States, and accordingly the entity is a domestic entity for purposes of Treasury Regulations section 301.7701-3.

Line 7 — Date Entity First Had More Than One Owner (If Not Already in Existence)

Date of formation (or date entity first had more than one owner):

September 15, 2025

This is the target formation date for the filing of the Delaware Certificate of Limited Partnership with the Delaware Secretary of State. On this date, the entity will come into existence under Delaware law and will have both a general partner (Solara Consolidated Master Fund GP LLC) and at least one limited partner, thereby constituting an entity with more than one owner. The Certificate of Limited Partnership is being prepared by Delaware counsel and will be filed electronically with the Delaware Division of Corporations on or about September 15, 2025.

Line 8 — Elected Classification

Check the box for the classification elected:

• [X] Partnership

• [ ] Association taxable as a corporation

• [ ] Disregarded entity

Explanation: Solara Consolidated Master Fund LP elects to be classified as a partnership for U.S. federal income tax purposes under Treasury Regulations section 301.7701-3. This election is consistent with the entity's legal form as a Delaware limited partnership with multiple members. Partnership classification ensures that the entity will not be subject to entity-level federal income tax and that all items of income, gain, loss, deduction, and credit will be allocated to and reported by its partners in accordance with the partnership agreement and Subchapter K of the Internal Revenue Code (sections 701 through 777).

Line 9 — Effective Date of Election

Effective date of election:

September 15, 2025

The effective date of this election has been coordinated with the entity's formation date, which is the date the Delaware Certificate of Limited Partnership is to be filed with the Delaware Secretary of State. By selecting September 15, 2025, as the effective date, the partnership classification of Solara Consolidated Master Fund LP will be in effect from the moment of its formation, and prior to the commencement of any of the contribution transactions contemplated in the multi-step reorganization of the Solara Digital Infrastructure LP fund platform. Specifically, the effective date ensures that partnership classification is established before the following reorganization transaction steps:

• Step 2 — Contribution of assets by Solara Digital Partners Fund IV-A (Cayman) LP: October 1, 2025

• Step 3 — Contribution of assets by Solara Digital Partners Fund IV-B (Luxembourg) SCSp: October 15, 2025

• Step 4 — Contribution of assets by Solara Digital Partners Fund V-A (Cayman) LP and Solara Digital Partners Fund V-B (Luxembourg) SCSp: November 1, 2025

• Step 5 — Dissolutions of legacy offshore vehicles and limited partner migration to new feeder vehicles: December 1, 2025

The effective date of September 15, 2025, satisfies the timing requirements of Treasury Regulations section 301.7701-3(c)(1)(iii), which provides that the effective date specified on a Form 8832 election cannot be more than 75 days prior to the date the election is filed, and cannot be more than 12 months after the date the election is filed. This Form 8832 is expected to be filed on or promptly after September 15, 2025, and in any event within 75 days of the effective date, thereby satisfying both prongs of the timing requirement.

Line 10 — Name and Title of Contact Person

Viktor Raines serves as the Managing Partner and Founder of Solara Digital Infrastructure LP and is the authorized individual responsible for the formation and governance of Solara Consolidated Master Fund LP and its general partner entity. Mr. Raines is authorized to execute this Form 8832 election on behalf of the entity and to act as the primary contact person for all communications with the Internal Revenue Service regarding this election.

Line 11 — Contact Person's Address (If Different from Line 5)

The contact person's address for purposes of this Form 8832 is the same as the address provided on Line 5:

1200 Market Street, Suite 3400 Wilmington, DE 19801

Alternatively, correspondence from the Internal Revenue Service regarding this Form 8832 election may be directed to the entity's authorized representatives, as designated on the attached Form 2848, Power of Attorney and Declaration of Representative:

Leonard Cross Partner, Tax Department Calderwood & Harkness LLP 1900 K Street NW, Suite 1100 Washington, DC 20006 Telephone: (202) 555-0231 CAF No.: [To be inserted]

Sylvia Hartwell Of Counsel, Tax Department Calderwood & Harkness LLP 600 Lexington Avenue, 38th Floor New York, NY 10022 Telephone: (212) 555-0394 CAF No.: [To be inserted]

A completed Form 2848 authorizing Messrs. Cross and Hartwell (and such other attorneys and professionals at Calderwood & Harkness LLP as may be designated therein) to represent Solara Consolidated Master Fund LP before the Internal Revenue Service with respect to this Form 8832 election and related matters will be filed concurrently with this election or has been previously filed and is currently in effect.

PART II — LATE ELECTION RELIEF

This section is not completed.

Part II of Form 8832 is reserved for entities seeking late election relief under Revenue Procedure 2009-41, 2009-39 I.R.B. 439, or successor guidance issued by the Internal Revenue Service. Because this election is being filed timely in connection with the initial formation of Solara Consolidated Master Fund LP, and the election is being filed within 75 days after the entity's formation date of September 15, 2025, no late-election relief is required. All applicable timing requirements under Treasury Regulations section 301.7701-3(c)(1)(iii) are satisfied, and accordingly, all boxes and fields in Part II are left blank.

CONSENT STATEMENT AND SIGNATURES

Consent of Each Member

Under Treasury Regulations section 301.7701-3(c)(2), each member of an eligible entity (or an authorized officer, manager, or member of the entity who is authorized under local law or the entity's organizational documents to make the election on behalf of the entity) must sign the Form 8832 election or consent to the election. The following sets forth the consent information for the members of Solara Consolidated Master Fund LP.

General Partner:

The general partner of Solara Consolidated Master Fund LP is Solara Consolidated Master Fund GP LLC, a Delaware limited liability company to be formed on September 15, 2025. Solara Consolidated Master Fund GP LLC is a single-member limited liability company whose sole member and manager is Solara Digital Infrastructure GP LLC, a Delaware limited liability company. The Managing Partner of Solara Digital Infrastructure GP LLC is Viktor Raines, who is authorized under the organizational documents of each entity in the chain of authority to execute this Form 8832 election on behalf of Solara Consolidated Master Fund LP and all of its members.

Initial Limited Partners:

The initial limited partners of Solara Consolidated Master Fund LP will include the following legacy offshore fund vehicles, which will contribute portfolio assets to the Master Fund in Steps 2 through 4 of the reorganization:

1. Solara Digital Partners Fund IV-A (Cayman) LP — Cayman Islands exempted limited partnership (EIN: 98-6241503). Contribution of assets expected on October 1, 2025 (Step 2).

2. Solara Digital Partners Fund IV-B (Luxembourg) SCSp — Luxembourg special limited partnership (société en commandite spéciale) (EIN: 98-6241571). Contribution of assets expected on October 15, 2025 (Step 3).

3. Solara Digital Partners Fund V-A (Cayman) LP — Cayman Islands exempted limited partnership (EIN: 98-7891234). Contribution of assets expected on November 1, 2025 (Step 4).

4. Solara Digital Partners Fund V-B (Luxembourg) SCSp — Luxembourg special limited partnership (société en commandite spéciale) (EIN: 98-7891267). Contribution of assets expected on November 1, 2025 (Step 4).

Following the completion of Step 5 of the reorganization (expected December 1, 2025), the limited partner interests in Solara Consolidated Master Fund LP will transition to include the following newly formed feeder vehicles:

• Solara International Feeder (Cayman) LP — Cayman Islands exempted limited partnership (to be formed; feeder vehicle for non-U.S. investors)

• Solara Tax-Exempt Feeder (Cayman) LP — Cayman Islands exempted limited partnership (to be formed; feeder vehicle for U.S. tax-exempt investors, including pension funds, endowments, and similar organizations)

Each initial limited partner (or an authorized officer, general partner, or manager thereof) has consented to this Form 8832 election, or alternatively, the general partner of Solara Consolidated Master Fund LP is authorized under the terms of the Agreement of Limited Partnership of Solara Consolidated Master Fund LP (to be dated as of September 15, 2025) to execute this election on behalf of the partnership and all of its partners without the requirement of separate signature pages from each limited partner. Section 6.2(h) of the Agreement of Limited Partnership expressly authorizes the General Partner to make all tax elections on behalf of the Partnership, including elections under Treasury Regulations section 301.7701-3.

Signature block. 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 Solara Consolidated Master Fund LP.

SOLARA CONSOLIDATED MASTER FUND GP LLC (as General Partner of Solara Consolidated Master Fund LP)

By: Solara Digital Infrastructure GP LLC, its Sole Member

By: ________

Name: Viktor Raines

Title: Managing Partner, Solara Digital Infrastructure GP LLC, as sole member of Solara Consolidated Master Fund GP LLC, the general partner of Solara Consolidated Master Fund LP

Date: ________

Additional Consents: To the extent the Internal Revenue Service requires separate signatures or consents of each member of Solara Consolidated Master Fund LP, a supplemental consent statement signed by each initial limited partner (or an authorized officer, general partner, or manager thereof) will be attached as an addendum to this Form 8832 at the time of filing. In the alternative, the signature of the General Partner above is made pursuant to the authority granted under Section 6.2(h) of the Agreement of Limited Partnership of Solara Consolidated Master Fund LP, which authorizes the General Partner to make all tax elections on behalf of the Partnership and its partners.

ATTACHMENT / ADDENDUM — SUPPLEMENTAL INFORMATION

The following supplemental information is provided in connection with the Form 8832, Entity Classification Election, filed by Solara Consolidated Master Fund LP. This addendum is attached to and made a part of the Form 8832 election.

I. Entity Description

II. Business Purpose

Solara Consolidated Master Fund LP is being formed as the master fund vehicle in a cross-border reorganization of the Solara Digital Infrastructure LP fund platform (the "Reorganization"). The purpose of the Reorganization is to consolidate the portfolio assets currently held by four legacy offshore fund vehicles into a single domestic master fund structure, in order to simplify the fund platform's organizational architecture, reduce administrative and compliance costs, improve operational efficiency, and facilitate future capital raising and investment activity.

Legacy Fund Vehicles. The four legacy offshore fund vehicles whose assets will be contributed to the Master Fund are as follows:

1. Solara Digital Partners Fund IV-A (Cayman) LP — a Cayman Islands exempted limited partnership formed in 2019. Fund IV-A holds a diversified portfolio of investments in digital infrastructure and enterprise SaaS companies, primarily through equity and equity-linked instruments.

2. Solara Digital Partners Fund IV-B (Luxembourg) SCSp — a Luxembourg special limited partnership (société en commandite spéciale) formed in 2019. Fund IV-B holds investments substantially similar to those held by Fund IV-A, structured through Luxembourg for European investor access and regulatory purposes.

3. Solara Digital Partners Fund V-A (Cayman) LP — a Cayman Islands exempted limited partnership formed in 2022. Fund V-A represents the successor fund generation and holds investments in later-stage digital infrastructure assets and growth-stage SaaS platforms.

4. Solara Digital Partners Fund V-B (Luxembourg) SCSp — a Luxembourg special limited partnership (société en commandite spéciale) formed in 2022. Fund V-B holds investments substantially similar to those held by Fund V-A, structured through Luxembourg for European investor access and regulatory purposes.

Aggregate Asset Information. The following table summarizes the aggregate asset values and other financial information for the assets to be contributed to the Master Fund:

Portfolio Composition. Upon completion of the Reorganization, the Master Fund's portfolio will consist of interests in 23 operating companies in the digital infrastructure and enterprise SaaS sectors. The five largest portfolio holdings, by fair market value, are as follows:

1. Veridian Edge Computing Corp. — a Delaware corporation engaged in the development, deployment, and operation of edge computing infrastructure and services. Fair market value: $1.12 billion.

2. NovaBright Data Systems Inc. — a Delaware corporation engaged in the ownership, development, and operation of hyperscale data center facilities across North America and Western Europe. Fair market value: $890 million.

3. Thorngate Fiber Networks LP — a Delaware limited partnership engaged in the construction, operation, and leasing of fiber-optic network infrastructure in major metropolitan areas. Fair market value: $670 million.

4. Helix SaaS Holdings Ltd. — a Cayman Islands exempted company serving as a holding company for a portfolio of enterprise SaaS businesses across multiple verticals. Fair market value: $445 million.

5. Crestline Cloud Solutions LLC — a Delaware limited liability company engaged in the development and operation of a cloud-based SaaS platform for enterprise resource planning and workflow automation. Fair market value: €340 million (approximately $367 million at current exchange rates).

The remaining 18 portfolio companies represent investments ranging from approximately $35 million to $310 million in fair market value, across sub-sectors including managed hosting services, cybersecurity infrastructure, telecommunications software, enterprise data analytics, and cloud storage solutions.

III. Reorganization Transaction Steps

The formation of Solara Consolidated Master Fund LP and the filing of this Form 8832 election are part of a coordinated multi-step reorganization. The anticipated transaction steps and their expected dates are as follows:

Step 1 — Formation of New Entities (September 15, 2025): Formation of Solara Consolidated Master Fund GP LLC (general partner) and Solara Consolidated Master Fund LP (master fund), each under Delaware law. Filing of this Form 8832 election to establish partnership classification.

Step 2 — Fund IV-A Cayman Contribution (October 1, 2025): Solara Digital Partners Fund IV-A (Cayman) LP contributes its portfolio assets to Solara Consolidated Master Fund LP in exchange for limited partnership interests. The contribution is intended to qualify as a tax-free contribution under section 721(a) of the Internal Revenue Code.

Step 3 — Fund IV-B Luxembourg Contribution (October 15, 2025): Solara Digital Partners Fund IV-B (Luxembourg) SCSp contributes its portfolio assets to Solara Consolidated Master Fund LP in exchange for limited partnership interests. The contribution is intended to qualify as a tax-free contribution under section 721(a) of the Internal Revenue Code.

Step 4 — Fund V Offshore Contributions (November 1, 2025): Solara Digital Partners Fund V-A (Cayman) LP and Solara Digital Partners Fund V-B (Luxembourg) SCSp each contribute their respective portfolio assets to Solara Consolidated Master Fund LP in exchange for limited partnership interests. Each contribution is intended to qualify as a tax-free contribution under section 721(a) of the Internal Revenue Code.

Step 5 — Dissolutions and LP Migration (December 1, 2025): The legacy offshore fund vehicles (Funds IV-A, IV-B, V-A, and V-B) are dissolved and wound up in accordance with their respective governing documents and applicable Cayman Islands and Luxembourg law. The investors in the legacy vehicles receive interests in the newly formed feeder vehicles (Solara International Feeder (Cayman) LP and Solara Tax-Exempt Feeder (Cayman) LP), which in turn hold limited partnership interests in Solara Consolidated Master Fund LP.

IV. Coordination with Private Letter Ruling Request

This Form 8832 election is being filed as part of a coordinated tax planning strategy for which Solara Digital Infrastructure LP has engaged Calderwood & Harkness LLP (engagement number 20250527-SDILP-PLR) to prepare and submit a private letter ruling ("PLR") request to the Internal Revenue Service, Office of the Associate Chief Counsel (International).

The PLR request is targeted for submission on August 15, 2025, and seeks confirmation from the IRS on a number of issues arising from the Reorganization, including, among other things:

• Ruling 8: Confirmation that Solara Consolidated Master Fund LP will be classified as a partnership for U.S. federal income tax purposes under Treasury Regulations section 301.7701-3, consistent with this Form 8832 election.

• Additional rulings concerning the tax treatment of the contribution transactions under section 721(a), the allocation of built-in gain under section 704(c), the treatment of liabilities assumed under section 752, and the application of the anti-abuse rules under Treasury Regulations section 1.701-2.

The effective date of this Form 8832 election (September 15, 2025) has been carefully coordinated to ensure that partnership classification of the Master Fund is established and in effect before any of the contribution transactions occur (beginning with Step 2 on October 1, 2025). This sequencing is essential to the tax analysis supporting the PLR request, as the characterization of the contribution transactions under section 721(a) depends upon the Master Fund being classified as a partnership at the time each contribution is made.

V. Related Form 8832 Elections

Two additional Form 8832 elections are being filed concurrently (or will be filed promptly following formation) for related entities formed as part of the same Reorganization:

1. Solara International Feeder (Cayman) LP — a Cayman Islands exempted limited partnership to be formed in connection with Step 5 of the Reorganization. This entity will elect to be classified as a partnership for U.S. federal income tax purposes under Treasury Regulations section 301.7701-3. The entity will serve as the feeder vehicle through which non-U.S. investors hold indirect interests in Solara Consolidated Master Fund LP. As a foreign eligible entity with two or more members, its default classification under Treasury Regulations section 301.7701-3(b)(2)(i) would be partnership; the affirmative election is being made for certainty and coordination with the PLR request.

2. Solara Tax-Exempt Feeder (Cayman) LP — a Cayman Islands exempted limited partnership to be formed in connection with Step 5 of the Reorganization. This entity will elect to be classified as a partnership for U.S. federal income tax purposes under Treasury Regulations section 301.7701-3. The entity will serve as the feeder vehicle through which U.S. tax-exempt investors (including pension funds, endowments, foundations, and similar organizations) hold indirect interests in Solara Consolidated Master Fund LP. The use of a separate feeder for tax-exempt investors is designed to facilitate compliance with the unrelated business taxable income ("UBTI") rules under sections 511 through 514 of the Internal Revenue Code and to provide appropriate reporting and allocation mechanisms for such investors.

VI. Regulatory References

The following regulatory provisions are relevant to this Form 8832 election:

• Treas. Reg. § 301.7701-3(a): Solara Consolidated Master Fund LP is an "eligible entity" within the meaning of this regulation — that is, a business entity that is not classified as a corporation under Treasury Regulations section 301.7701-2(b). A Delaware limited partnership is not included in the list of per se corporations set forth in Treasury Regulations section 301.7701-2(b)(1) through (b)(8), and accordingly is an eligible entity that may elect its classification for U.S. federal income tax purposes.

• Treas. Reg. § 301.7701-3(b)(1): As a domestic eligible entity with two or more members, the default classification of Solara Consolidated Master Fund LP under this regulation would be partnership. This Form 8832 election confirms and affirmatively establishes that default classification, thereby precluding any ambiguity and ensuring that the entity's partnership status is documented on file with the Internal Revenue Service from the date of the entity's formation.

• Treas. Reg. § 301.7701-3(c)(1)(i): This regulation provides that an eligible entity may elect its classification by filing Form 8832 with the IRS Service Center designated in the form instructions. The election is being made by filing this Form 8832 in accordance with the applicable instructions.

• Treas. Reg. § 301.7701-3(c)(1)(iii): This regulation governs the effective date of a Form 8832 election. The effective date specified on the election cannot be more than 75 days prior to the date the election is filed, and cannot be more than 12 months after the date the election is filed. The effective date of September 15, 2025, specified on this election is the date of the entity's formation and is within the permitted window, as this form is being filed on or promptly after September 15, 2025.

• Treas. Reg. § 301.7701-3(c)(2): This regulation requires that each member of the eligible entity (or an officer, manager, or member authorized to make the election) consent to the election. As described in the Consent Statement above, the General Partner of Solara Consolidated Master Fund LP is authorized under the Agreement of Limited Partnership to make this election on behalf of the Partnership and all of its partners.

FILING INSTRUCTIONS AND COVER NOTES

FOR INTERNAL USE ONLY — CALDERWOOD & HARKNESS LLP ENGAGEMENT TEAM This section is not part of the Form 8832 filed with the Internal Revenue Service.

Filing Address. Per the instructions to Form 8832 (Rev. January 2012), the completed and executed Form 8832 should be filed with the Internal Revenue Service Center designated for the entity's principal office location. Based on the entity's principal office address of 1200 Market Street, Suite 3400, Wilmington, DE 19801, the applicable IRS Service Center is:

Department of the Treasury Internal Revenue Service Center Kansas City, MO 64999

The form should be sent by certified mail, return receipt requested, or by a designated private delivery service recognized by the IRS under section 7502(f) of the Internal Revenue Code, to ensure proof of timely filing.

Copies and Distribution

1. Original: Filed with the IRS Service Center at the address above.

2. Tax Return Copy: One copy of the filed Form 8832 (including the confirmation letter received from the IRS, if any) must be attached to the entity's initial federal income tax return. Because Solara Consolidated Master Fund LP is electing partnership classification, the initial return will be Form 1065, U.S. Return of Partnership Income, for the short tax year beginning September 15, 2025 and ending December 31, 2025. The Form 1065 is due on or before March 15, 2026 (subject to any extension filed on Form 7004).

3. Engagement File Copy: The original executed Form 8832 and the IRS confirmation letter (when received) should be maintained in the Calderwood & Harkness LLP engagement files under matter number 20250527-SDILP-PLR. Both the Washington, D.C. and New York offices should retain copies.

4. Client Records: A copy of the executed Form 8832 and IRS confirmation should be provided to the client for inclusion in the permanent tax records of Solara Digital Infrastructure LP and Solara Consolidated Master Fund LP.

Responsible Attorneys.

Garrett Simmons, Working Associate in the New York office, has primary responsibility for the preparation, review, and filing of this Form 8832, under the supervision of Leonard Cross, Responsible Partner in the Washington, D.C. office. Sylvia Hartwell, Of Counsel in the New York office, has reviewed the election for consistency with the PLR submission and the overall reorganization transaction structure.

Coordination Notes.

• Closing Checklist: The filing of this Form 8832 should be tracked as an action item on the Closing Checklist — PLR Submission maintained by the engagement team. The checklist item should be updated to reflect: (a) the date of execution by Viktor Raines; (b) the date of filing with the IRS; (c) the date of receipt of IRS confirmation (if issued); and (d) the date a copy is attached to the initial Form 1065.

• Issue Tracking Log: The partnership classification of Solara Consolidated Master Fund LP is tracked as Issue #8 on the Issue Tracking Log maintained by the engagement team. Upon receipt of IRS confirmation of the Form 8832 election (or, in the alternative, upon filing of the election without objection), Issue #8 should be updated to "Resolved — Election Filed" status.

• Concurrent Filings: The engagement team should coordinate the filing of this Form 8832 with the concurrent filing of Form 8832 elections for Solara International Feeder (Cayman) LP and Solara Tax-Exempt Feeder (Cayman) LP, as well as the Form SS-4 application for EIN for Solara Consolidated Master Fund LP. All filings should be made on the same date to the extent practicable.

• PLR Cross-Reference: A copy of the filed Form 8832 and proof of filing should be included in the appendix to the PLR submission package as Exhibit H (Entity Classification Elections), in support of Ruling 8 requested in the PLR.

• Delaware Filing Confirmation: Filing of this Form 8832 should not occur until confirmation has been received from the Delaware Secretary of State that the Certificate of Limited Partnership for Solara Consolidated Master Fund LP has been accepted and filed. The entity must be in existence under Delaware law before the Form 8832 election can be validly made.

End of Form 8832 — Entity Classification Election Solara Consolidated Master Fund LP Prepared by Calderwood & Harkness LLP Engagement No. 20250527-SDILP-PLR

Field	Entry
Number, street, and room or suite no.	1200 Market Street, Suite 3400
City or town	Wilmington
State	DE
ZIP code	19801
Field	Entry
Name	Viktor Raines
Title	Managing Partner, Solara Digital Infrastructure GP LLC (in its capacity as the sole member of Solara Consolidated Master Fund GP LLC, the general partner of Solara Consolidated Master Fund LP)
Telephone number	(302) 555-0147
Item	Description
Full Legal Name	Solara Consolidated Master Fund LP
Entity Type	Delaware limited partnership
Jurisdiction of Formation	State of Delaware
Governing Law	Delaware Revised Uniform Limited Partnership Act, 6 Del. C. § 17-101 et seq.
Date of Formation	September 15, 2025 (target date)
Formation Document	Certificate of Limited Partnership to be filed with the Delaware Secretary of State, Division of Corporations
Registered Agent	Capitol Registered Agents Inc., 850 New Burton Road, Suite 201, Dover, DE 19904
General Partner	Solara Consolidated Master Fund GP LLC, a Delaware limited liability company
Principal Office	1200 Market Street, Suite 3400, Wilmington, DE 19801
EIN	Applied for (Form SS-4 to be filed concurrently with entity formation)
Fiscal Year	Calendar year (December 31 year-end)
Initial Tax Year	Short period from September 15, 2025 through December 31, 2025
Category	Amount
Total fair market value of assets to be contributed	$7.75 billion
Total adjusted tax basis of assets to be contributed	$6.03 billion

Total built-in gain	$1.72 billion
Aggregate liabilities to be assumed by the Master Fund	$1.34 billion
Role	Name	Office	Contact
Responsible Partner	Leonard Cross	Calderwood & Harkness LLP, Washington, D.C.	(202) 555-0231
Working Associate	Garrett Simmons	Calderwood & Harkness LLP, New York	(212) 555-0417
Of Counsel (Review)	Sylvia Hartwell	Calderwood & Harkness LLP, New York	(212) 555-0394

FORM 8832
Entity Classification Election
Department of the Treasury — Internal Revenue Service
Under Regulations Section 301.7701-3
OMB No. 1545-1516
NOTE: This document is a completed Form 8832 reflecting all entries as they would appear on the official IRS Form 8832 (Rev. January 2012). This draft has been prepared by Calderwood & Harkness LLP for review and execution by the authorized representatives of Solara Consolidated Master Fund LP. All entries correspond to the applicable lines and checkboxes on the official printed form. Upon finalization, this information will be transcribed onto the official IRS form for filing, or this document may be submitted in lieu thereof to the extent permitted by applicable IRS instructions and guidance. References to "check box" or "checked" below indicate the selection that will be marked on the official form.
PART I — ELECTION INFORMATION
Line 1 — Type of Election
Check the box that applies:
•  [X] Initial classification by a newly formed entity
•  [ ] Change in current classification
•  [ ] Late election relief under Revenue Procedure 2009-41 or successor guidance
Explanation: Solara Consolidated Master Fund LP is a newly formed Delaware limited partnership. The entity does not currently exist and is expected to be formed on September 15, 2025, by the filing of a Certificate of Limited Partnership with the Delaware Secretary of State. This election constitutes an initial classification election under Treasury Regulations section 301.7701-3(c), and is not a change in classification of an existing entity. Because the entity is newly formed, no prior classification exists, and this election is being submitted to affirmatively establish the entity's classification for U.S. federal income tax purposes from the date of its formation.
Line 2 — Form of Entity Eligible to Make Election
Check the box that applies:
•  [X] A domestic eligible entity electing to be classified as a partnership
•  [ ] A domestic eligible entity electing to be classified as an association taxable as a corporation
•  [ ] A domestic eligible entity with a single owner electing to be disregarded as a separate entity
•  [ ] A foreign eligible entity electing to be classified as a partnership
•  [ ] A foreign eligible entity electing to be classified as an association taxable as a corporation
•  [ ] A foreign eligible entity with a single owner electing to be disregarded as a separate entity
Explanation: Solara Consolidated Master Fund LP is a domestic eligible entity (formed under the laws of the State of Delaware) with more than one member (a general partner and multiple limited partners). The entity is electing to be classified as a partnership for U.S. federal income tax purposes. A domestic limited partnership with two or more members is an "eligible entity" within the meaning of Treasury Regulations section 301.7701-3(a), as it is a business entity that is not classified as a corporation under Treasury Regulations section 301.7701-2(b) (i.e., it is not a per se corporation). While partnership classification would also be the default classification for a domestic eligible entity with two or more members under Treasury Regulations section 301.7701-3(b)(1), this affirmative election is being made to confirm and lock in such classification in connection with a multi-step reorganization transaction involving the contribution of assets with a total fair market value of approximately $7.75 billion.
Line 3 — Disregarded Entity Information
Not applicable. This line is left blank. Solara Consolidated Master Fund LP will have more than one member (owner) as of its formation date and is not electing to be classified as a disregarded entity. The entity will have both a general partner (Solara Consolidated Master Fund GP LLC) and multiple limited partners, as described further in the Consent Statement section below and in the attached Supplemental Information addendum.
Line 4 — Name and Employer Identification Number (EIN) of Eligible Entity Making Election
Name of Eligible Entity:
Solara Consolidated Master Fund LP
Employer Identification Number (EIN):
Applied For
(Application for EIN is pending. Form SS-4, Application for Employer Identification Number, will be filed with the Internal Revenue Service in connection with the formation of the entity on or about September 15, 2025. If the EIN has been assigned prior to the filing date of this Form 8832, the assigned EIN will be inserted on the official filed version of this form. If the EIN has not yet been received, this form will be filed with the notation "Applied For" in the EIN field, consistent with the instructions to Form 8832.)
Line 5 — Address of Eligible Entity
This is the headquarters address of Solara Digital Infrastructure LP, the fund platform sponsor, which will serve as the principal office of Solara Consolidated Master Fund LP. All correspondence from the Internal Revenue Service regarding this Form 8832 election should be directed to this address unless an authorized representative has been designated on a valid Form 2848, Power of Attorney and Declaration of Representative (see Line 11 below for additional authorized representative addresses).
Line 6 — Type of Entity
Check the box that applies:
•  [X] A domestic entity (formed or organized in the United States or under the law of the United States or of any State)
•  [ ] A foreign entity (formed or organized under the law of a foreign country)
Explanation: Solara Consolidated Master Fund LP is a domestic entity. It will be formed as a limited partnership under the Delaware Revised Uniform Limited Partnership Act, 6 Del. C. § 17-101 et seq., by the filing of a Certificate of Limited Partnership with the Secretary of State of the State of Delaware. Delaware is a State of the United States, and accordingly the entity is a domestic entity for purposes of Treasury Regulations section 301.7701-3.
Line 7 — Date Entity First Had More Than One Owner (If Not Already in Existence)
Date of formation (or date entity first had more than one owner):
September 15, 2025
This is the target formation date for the filing of the Delaware Certificate of Limited Partnership with the Delaware Secretary of State. On this date, the entity will come into existence under Delaware law and will have both a general partner (Solara Consolidated Master Fund GP LLC) and at least one limited partner, thereby constituting an entity with more than one owner. The Certificate of Limited Partnership is being prepared by Delaware counsel and will be filed electronically with the Delaware Division of Corporations on or about September 15, 2025.
Line 8 — Elected Classification
Check the box for the classification elected:
•  [X] Partnership
•  [ ] Association taxable as a corporation
•  [ ] Disregarded entity
Explanation: Solara Consolidated Master Fund LP elects to be classified as a partnership for U.S. federal income tax purposes under Treasury Regulations section 301.7701-3. This election is consistent with the entity's legal form as a Delaware limited partnership with multiple members. Partnership classification ensures that the entity will not be subject to entity-level federal income tax and that all items of income, gain, loss, deduction, and credit will be allocated to and reported by its partners in accordance with the partnership agreement and Subchapter K of the Internal Revenue Code (sections 701 through 777).
Line 9 — Effective Date of Election
Effective date of election:
September 15, 2025
The effective date of this election has been coordinated with the entity's formation date, which is the date the Delaware Certificate of Limited Partnership is to be filed with the Delaware Secretary of State. By selecting September 15, 2025, as the effective date, the partnership classification of Solara Consolidated Master Fund LP will be in effect from the moment of its formation, and prior to the commencement of any of the contribution transactions contemplated in the multi-step reorganization of the Solara Digital Infrastructure LP fund platform. Specifically, the effective date ensures that partnership classification is established before the following reorganization transaction steps:
•  Step 2 — Contribution of assets by Solara Digital Partners Fund IV-A (Cayman) LP: October 1, 2025
•  Step 3 — Contribution of assets by Solara Digital Partners Fund IV-B (Luxembourg) SCSp: October 15, 2025
•  Step 4 — Contribution of assets by Solara Digital Partners Fund V-A (Cayman) LP and Solara Digital Partners Fund V-B (Luxembourg) SCSp: November 1, 2025
•  Step 5 — Dissolutions of legacy offshore vehicles and limited partner migration to new feeder vehicles: December 1, 2025
The effective date of September 15, 2025, satisfies the timing requirements of Treasury Regulations section 301.7701-3(c)(1)(iii), which provides that the effective date specified on a Form 8832 election cannot be more than 75 days prior to the date the election is filed, and cannot be more than 12 months after the date the election is filed. This Form 8832 is expected to be filed on or promptly after September 15, 2025, and in any event within 75 days of the effective date, thereby satisfying both prongs of the timing requirement.
Line 10 — Name and Title of Contact Person
Viktor Raines serves as the Managing Partner and Founder of Solara Digital Infrastructure LP and is the authorized individual responsible for the formation and governance of Solara Consolidated Master Fund LP and its general partner entity. Mr. Raines is authorized to execute this Form 8832 election on behalf of the entity and to act as the primary contact person for all communications with the Internal Revenue Service regarding this election.
Line 11 — Contact Person's Address (If Different from Line 5)
The contact person's address for purposes of this Form 8832 is the same as the address provided on Line 5:
1200 Market Street, Suite 3400 Wilmington, DE 19801
Alternatively, correspondence from the Internal Revenue Service regarding this Form 8832 election may be directed to the entity's authorized representatives, as designated on the attached Form 2848, Power of Attorney and Declaration of Representative:
Leonard Cross Partner, Tax Department Calderwood & Harkness LLP 1900 K Street NW, Suite 1100 Washington, DC 20006 Telephone: (202) 555-0231 CAF No.: [To be inserted]
Sylvia Hartwell Of Counsel, Tax Department Calderwood & Harkness LLP 600 Lexington Avenue, 38th Floor New York, NY 10022 Telephone: (212) 555-0394 CAF No.: [To be inserted]
A completed Form 2848 authorizing Messrs. Cross and Hartwell (and such other attorneys and professionals at Calderwood & Harkness LLP as may be designated therein) to represent Solara Consolidated Master Fund LP before the Internal Revenue Service with respect to this Form 8832 election and related matters will be filed concurrently with this election or has been previously filed and is currently in effect.
PART II — LATE ELECTION RELIEF
This section is not completed.
Part II of Form 8832 is reserved for entities seeking late election relief under Revenue Procedure 2009-41, 2009-39 I.R.B. 439, or successor guidance issued by the Internal Revenue Service. Because this election is being filed timely in connection with the initial formation of Solara Consolidated Master Fund LP, and the election is being filed within 75 days after the entity's formation date of September 15, 2025, no late-election relief is required. All applicable timing requirements under Treasury Regulations section 301.7701-3(c)(1)(iii) are satisfied, and accordingly, all boxes and fields in Part II are left blank.
CONSENT STATEMENT AND SIGNATURES
Consent of Each Member
Under Treasury Regulations section 301.7701-3(c)(2), each member of an eligible entity (or an authorized officer, manager, or member of the entity who is authorized under local law or the entity's organizational documents to make the election on behalf of the entity) must sign the Form 8832 election or consent to the election. The following sets forth the consent information for the members of Solara Consolidated Master Fund LP.
General Partner:
The general partner of Solara Consolidated Master Fund LP is Solara Consolidated Master Fund GP LLC, a Delaware limited liability company to be formed on September 15, 2025. Solara Consolidated Master Fund GP LLC is a single-member limited liability company whose sole member and manager is Solara Digital Infrastructure GP LLC, a Delaware limited liability company. The Managing Partner of Solara Digital Infrastructure GP LLC is Viktor Raines, who is authorized under the organizational documents of each entity in the chain of authority to execute this Form 8832 election on behalf of Solara Consolidated Master Fund LP and all of its members.
Initial Limited Partners:
The initial limited partners of Solara Consolidated Master Fund LP will include the following legacy offshore fund vehicles, which will contribute portfolio assets to the Master Fund in Steps 2 through 4 of the reorganization:
1.  Solara Digital Partners Fund IV-A (Cayman) LP — Cayman Islands exempted limited partnership (EIN: 98-6241503). Contribution of assets expected on October 1, 2025 (Step 2).
2.  Solara Digital Partners Fund IV-B (Luxembourg) SCSp — Luxembourg special limited partnership (société en commandite spéciale) (EIN: 98-6241571). Contribution of assets expected on October 15, 2025 (Step 3).
3.  Solara Digital Partners Fund V-A (Cayman) LP — Cayman Islands exempted limited partnership (EIN: 98-7891234). Contribution of assets expected on November 1, 2025 (Step 4).
4.  Solara Digital Partners Fund V-B (Luxembourg) SCSp — Luxembourg special limited partnership (société en commandite spéciale) (EIN: 98-7891267). Contribution of assets expected on November 1, 2025 (Step 4).
Following the completion of Step 5 of the reorganization (expected December 1, 2025), the limited partner interests in Solara Consolidated Master Fund LP will transition to include the following newly formed feeder vehicles:
•  Solara International Feeder (Cayman) LP — Cayman Islands exempted limited partnership (to be formed; feeder vehicle for non-U.S. investors)
•  Solara Tax-Exempt Feeder (Cayman) LP — Cayman Islands exempted limited partnership (to be formed; feeder vehicle for U.S. tax-exempt investors, including pension funds, endowments, and similar organizations)
Each initial limited partner (or an authorized officer, general partner, or manager thereof) has consented to this Form 8832 election, or alternatively, the general partner of Solara Consolidated Master Fund LP is authorized under the terms of the Agreement of Limited Partnership of Solara Consolidated Master Fund LP (to be dated as of September 15, 2025) to execute this election on behalf of the partnership and all of its partners without the requirement of separate signature pages from each limited partner. Section 6.2(h) of the Agreement of Limited Partnership expressly authorizes the General Partner to make all tax elections on behalf of the Partnership, including elections under Treasury Regulations section 301.7701-3.
Signature block.  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 Solara Consolidated Master Fund LP.
SOLARA CONSOLIDATED MASTER FUND GP LLC (as General Partner of Solara Consolidated Master Fund LP)
By: Solara Digital Infrastructure GP LLC, its Sole Member
By: ________
Name: Viktor Raines
Title: Managing Partner, Solara Digital Infrastructure GP LLC, as sole member of Solara Consolidated Master Fund GP LLC, the general partner of Solara Consolidated Master Fund LP
Date: ________
Additional Consents: To the extent the Internal Revenue Service requires separate signatures or consents of each member of Solara Consolidated Master Fund LP, a supplemental consent statement signed by each initial limited partner (or an authorized officer, general partner, or manager thereof) will be attached as an addendum to this Form 8832 at the time of filing. In the alternative, the signature of the General Partner above is made pursuant to the authority granted under Section 6.2(h) of the Agreement of Limited Partnership of Solara Consolidated Master Fund LP, which authorizes the General Partner to make all tax elections on behalf of the Partnership and its partners.
ATTACHMENT / ADDENDUM — SUPPLEMENTAL INFORMATION
The following supplemental information is provided in connection with the Form 8832, Entity Classification Election, filed by Solara Consolidated Master Fund LP. This addendum is attached to and made a part of the Form 8832 election.
I. Entity Description
II. Business Purpose
Solara Consolidated Master Fund LP is being formed as the master fund vehicle in a cross-border reorganization of the Solara Digital Infrastructure LP fund platform (the "Reorganization"). The purpose of the Reorganization is to consolidate the portfolio assets currently held by four legacy offshore fund vehicles into a single domestic master fund structure, in order to simplify the fund platform's organizational architecture, reduce administrative and compliance costs, improve operational efficiency, and facilitate future capital raising and investment activity.
Legacy Fund Vehicles. The four legacy offshore fund vehicles whose assets will be contributed to the Master Fund are as follows:
1.  Solara Digital Partners Fund IV-A (Cayman) LP — a Cayman Islands exempted limited partnership formed in 2019. Fund IV-A holds a diversified portfolio of investments in digital infrastructure and enterprise SaaS companies, primarily through equity and equity-linked instruments.
2.  Solara Digital Partners Fund IV-B (Luxembourg) SCSp — a Luxembourg special limited partnership (société en commandite spéciale) formed in 2019. Fund IV-B holds investments substantially similar to those held by Fund IV-A, structured through Luxembourg for European investor access and regulatory purposes.
3.  Solara Digital Partners Fund V-A (Cayman) LP — a Cayman Islands exempted limited partnership formed in 2022. Fund V-A represents the successor fund generation and holds investments in later-stage digital infrastructure assets and growth-stage SaaS platforms.
4.  Solara Digital Partners Fund V-B (Luxembourg) SCSp — a Luxembourg special limited partnership (société en commandite spéciale) formed in 2022. Fund V-B holds investments substantially similar to those held by Fund V-A, structured through Luxembourg for European investor access and regulatory purposes.
Aggregate Asset Information. The following table summarizes the aggregate asset values and other financial information for the assets to be contributed to the Master Fund:
Portfolio Composition. Upon completion of the Reorganization, the Master Fund's portfolio will consist of interests in 23 operating companies in the digital infrastructure and enterprise SaaS sectors. The five largest portfolio holdings, by fair market value, are as follows:
1.  Veridian Edge Computing Corp. — a Delaware corporation engaged in the development, deployment, and operation of edge computing infrastructure and services. Fair market value: $1.12 billion.
2.  NovaBright Data Systems Inc. — a Delaware corporation engaged in the ownership, development, and operation of hyperscale data center facilities across North America and Western Europe. Fair market value: $890 million.
3.  Thorngate Fiber Networks LP — a Delaware limited partnership engaged in the construction, operation, and leasing of fiber-optic network infrastructure in major metropolitan areas. Fair market value: $670 million.
4.  Helix SaaS Holdings Ltd. — a Cayman Islands exempted company serving as a holding company for a portfolio of enterprise SaaS businesses across multiple verticals. Fair market value: $445 million.
5.  Crestline Cloud Solutions LLC — a Delaware limited liability company engaged in the development and operation of a cloud-based SaaS platform for enterprise resource planning and workflow automation. Fair market value: €340 million (approximately $367 million at current exchange rates).
The remaining 18 portfolio companies represent investments ranging from approximately $35 million to $310 million in fair market value, across sub-sectors including managed hosting services, cybersecurity infrastructure, telecommunications software, enterprise data analytics, and cloud storage solutions.
III. Reorganization Transaction Steps
The formation of Solara Consolidated Master Fund LP and the filing of this Form 8832 election are part of a coordinated multi-step reorganization. The anticipated transaction steps and their expected dates are as follows:
Step 1 — Formation of New Entities (September 15, 2025): Formation of Solara Consolidated Master Fund GP LLC (general partner) and Solara Consolidated Master Fund LP (master fund), each under Delaware law. Filing of this Form 8832 election to establish partnership classification.
Step 2 — Fund IV-A Cayman Contribution (October 1, 2025): Solara Digital Partners Fund IV-A (Cayman) LP contributes its portfolio assets to Solara Consolidated Master Fund LP in exchange for limited partnership interests. The contribution is intended to qualify as a tax-free contribution under section 721(a) of the Internal Revenue Code.
Step 3 — Fund IV-B Luxembourg Contribution (October 15, 2025): Solara Digital Partners Fund IV-B (Luxembourg) SCSp contributes its portfolio assets to Solara Consolidated Master Fund LP in exchange for limited partnership interests. The contribution is intended to qualify as a tax-free contribution under section 721(a) of the Internal Revenue Code.
Step 4 — Fund V Offshore Contributions (November 1, 2025): Solara Digital Partners Fund V-A (Cayman) LP and Solara Digital Partners Fund V-B (Luxembourg) SCSp each contribute their respective portfolio assets to Solara Consolidated Master Fund LP in exchange for limited partnership interests. Each contribution is intended to qualify as a tax-free contribution under section 721(a) of the Internal Revenue Code.
Step 5 — Dissolutions and LP Migration (December 1, 2025): The legacy offshore fund vehicles (Funds IV-A, IV-B, V-A, and V-B) are dissolved and wound up in accordance with their respective governing documents and applicable Cayman Islands and Luxembourg law. The investors in the legacy vehicles receive interests in the newly formed feeder vehicles (Solara International Feeder (Cayman) LP and Solara Tax-Exempt Feeder (Cayman) LP), which in turn hold limited partnership interests in Solara Consolidated Master Fund LP.
IV. Coordination with Private Letter Ruling Request
This Form 8832 election is being filed as part of a coordinated tax planning strategy for which Solara Digital Infrastructure LP has engaged Calderwood & Harkness LLP (engagement number 20250527-SDILP-PLR) to prepare and submit a private letter ruling ("PLR") request to the Internal Revenue Service, Office of the Associate Chief Counsel (International).
The PLR request is targeted for submission on August 15, 2025, and seeks confirmation from the IRS on a number of issues arising from the Reorganization, including, among other things:
•  Ruling 8: Confirmation that Solara Consolidated Master Fund LP will be classified as a partnership for U.S. federal income tax purposes under Treasury Regulations section 301.7701-3, consistent with this Form 8832 election.
•  Additional rulings concerning the tax treatment of the contribution transactions under section 721(a), the allocation of built-in gain under section 704(c), the treatment of liabilities assumed under section 752, and the application of the anti-abuse rules under Treasury Regulations section 1.701-2.
The effective date of this Form 8832 election (September 15, 2025) has been carefully coordinated to ensure that partnership classification of the Master Fund is established and in effect before any of the contribution transactions occur (beginning with Step 2 on October 1, 2025). This sequencing is essential to the tax analysis supporting the PLR request, as the characterization of the contribution transactions under section 721(a) depends upon the Master Fund being classified as a partnership at the time each contribution is made.
V. Related Form 8832 Elections
Two additional Form 8832 elections are being filed concurrently (or will be filed promptly following formation) for related entities formed as part of the same Reorganization:
1.  Solara International Feeder (Cayman) LP — a Cayman Islands exempted limited partnership to be formed in connection with Step 5 of the Reorganization. This entity will elect to be classified as a partnership for U.S. federal income tax purposes under Treasury Regulations section 301.7701-3. The entity will serve as the feeder vehicle through which non-U.S. investors hold indirect interests in Solara Consolidated Master Fund LP. As a foreign eligible entity with two or more members, its default classification under Treasury Regulations section 301.7701-3(b)(2)(i) would be partnership; the affirmative election is being made for certainty and coordination with the PLR request.
2.  Solara Tax-Exempt Feeder (Cayman) LP — a Cayman Islands exempted limited partnership to be formed in connection with Step 5 of the Reorganization. This entity will elect to be classified as a partnership for U.S. federal income tax purposes under Treasury Regulations section 301.7701-3. The entity will serve as the feeder vehicle through which U.S. tax-exempt investors (including pension funds, endowments, foundations, and similar organizations) hold indirect interests in Solara Consolidated Master Fund LP. The use of a separate feeder for tax-exempt investors is designed to facilitate compliance with the unrelated business taxable income ("UBTI") rules under sections 511 through 514 of the Internal Revenue Code and to provide appropriate reporting and allocation mechanisms for such investors.
VI. Regulatory References
The following regulatory provisions are relevant to this Form 8832 election:
•  Treas. Reg. § 301.7701-3(a): Solara Consolidated Master Fund LP is an "eligible entity" within the meaning of this regulation — that is, a business entity that is not classified as a corporation under Treasury Regulations section 301.7701-2(b). A Delaware limited partnership is not included in the list of per se corporations set forth in Treasury Regulations section 301.7701-2(b)(1) through (b)(8), and accordingly is an eligible entity that may elect its classification for U.S. federal income tax purposes.
•  Treas. Reg. § 301.7701-3(b)(1): As a domestic eligible entity with two or more members, the default classification of Solara Consolidated Master Fund LP under this regulation would be partnership. This Form 8832 election confirms and affirmatively establishes that default classification, thereby precluding any ambiguity and ensuring that the entity's partnership status is documented on file with the Internal Revenue Service from the date of the entity's formation.
•  Treas. Reg. § 301.7701-3(c)(1)(i): This regulation provides that an eligible entity may elect its classification by filing Form 8832 with the IRS Service Center designated in the form instructions. The election is being made by filing this Form 8832 in accordance with the applicable instructions.
•  Treas. Reg. § 301.7701-3(c)(1)(iii): This regulation governs the effective date of a Form 8832 election. The effective date specified on the election cannot be more than 75 days prior to the date the election is filed, and cannot be more than 12 months after the date the election is filed. The effective date of September 15, 2025, specified on this election is the date of the entity's formation and is within the permitted window, as this form is being filed on or promptly after September 15, 2025.
•  Treas. Reg. § 301.7701-3(c)(2): This regulation requires that each member of the eligible entity (or an officer, manager, or member authorized to make the election) consent to the election. As described in the Consent Statement above, the General Partner of Solara Consolidated Master Fund LP is authorized under the Agreement of Limited Partnership to make this election on behalf of the Partnership and all of its partners.
FILING INSTRUCTIONS AND COVER NOTES
FOR INTERNAL USE ONLY — CALDERWOOD & HARKNESS LLP ENGAGEMENT TEAM This section is not part of the Form 8832 filed with the Internal Revenue Service.
Filing Address.  Per the instructions to Form 8832 (Rev. January 2012), the completed and executed Form 8832 should be filed with the Internal Revenue Service Center designated for the entity's principal office location. Based on the entity's principal office address of 1200 Market Street, Suite 3400, Wilmington, DE 19801, the applicable IRS Service Center is:
Department of the Treasury Internal Revenue Service Center Kansas City, MO 64999
The form should be sent by certified mail, return receipt requested, or by a designated private delivery service recognized by the IRS under section 7502(f) of the Internal Revenue Code, to ensure proof of timely filing.
Copies and Distribution
1.  Original: Filed with the IRS Service Center at the address above.
2.  Tax Return Copy: One copy of the filed Form 8832 (including the confirmation letter received from the IRS, if any) must be attached to the entity's initial federal income tax return. Because Solara Consolidated Master Fund LP is electing partnership classification, the initial return will be Form 1065, U.S. Return of Partnership Income, for the short tax year beginning September 15, 2025 and ending December 31, 2025. The Form 1065 is due on or before March 15, 2026 (subject to any extension filed on Form 7004).
3.  Engagement File Copy: The original executed Form 8832 and the IRS confirmation letter (when received) should be maintained in the Calderwood & Harkness LLP engagement files under matter number 20250527-SDILP-PLR. Both the Washington, D.C. and New York offices should retain copies.
4.  Client Records: A copy of the executed Form 8832 and IRS confirmation should be provided to the client for inclusion in the permanent tax records of Solara Digital Infrastructure LP and Solara Consolidated Master Fund LP.
Responsible Attorneys.  
Garrett Simmons, Working Associate in the New York office, has primary responsibility for the preparation, review, and filing of this Form 8832, under the supervision of Leonard Cross, Responsible Partner in the Washington, D.C. office. Sylvia Hartwell, Of Counsel in the New York office, has reviewed the election for consistency with the PLR submission and the overall reorganization transaction structure.
Coordination Notes.  
•  Closing Checklist: The filing of this Form 8832 should be tracked as an action item on the Closing Checklist — PLR Submission maintained by the engagement team. The checklist item should be updated to reflect: (a) the date of execution by Viktor Raines; (b) the date of filing with the IRS; (c) the date of receipt of IRS confirmation (if issued); and (d) the date a copy is attached to the initial Form 1065.
•  Issue Tracking Log: The partnership classification of Solara Consolidated Master Fund LP is tracked as Issue #8 on the Issue Tracking Log maintained by the engagement team. Upon receipt of IRS confirmation of the Form 8832 election (or, in the alternative, upon filing of the election without objection), Issue #8 should be updated to "Resolved — Election Filed" status.
•  Concurrent Filings: The engagement team should coordinate the filing of this Form 8832 with the concurrent filing of Form 8832 elections for Solara International Feeder (Cayman) LP and Solara Tax-Exempt Feeder (Cayman) LP, as well as the Form SS-4 application for EIN for Solara Consolidated Master Fund LP. All filings should be made on the same date to the extent practicable.
•  PLR Cross-Reference: A copy of the filed Form 8832 and proof of filing should be included in the appendix to the PLR submission package as Exhibit H (Entity Classification Elections), in support of Ruling 8 requested in the PLR.
•  Delaware Filing Confirmation: Filing of this Form 8832 should not occur until confirmation has been received from the Delaware Secretary of State that the Certificate of Limited Partnership for Solara Consolidated Master Fund LP has been accepted and filed. The entity must be in existence under Delaware law before the Form 8832 election can be validly made.
End of Form 8832 — Entity Classification Election Solara Consolidated Master Fund LP Prepared by Calderwood & Harkness LLP Engagement No. 20250527-SDILP-PLR
Field | Entry
Number, street, and room or suite no. | 1200 Market Street, Suite 3400
City or town | Wilmington
State | DE
ZIP code | 19801
Field | Entry
Name | Viktor Raines
Title | Managing Partner, Solara Digital Infrastructure GP LLC (in its capacity as the sole member of Solara Consolidated Master Fund GP LLC, the general partner of Solara Consolidated Master Fund LP)
Telephone number | (302) 555-0147
Item | Description
Full Legal Name | Solara Consolidated Master Fund LP
Entity Type | Delaware limited partnership
Jurisdiction of Formation | State of Delaware
Governing Law | Delaware Revised Uniform Limited Partnership Act, 6 Del. C. § 17-101 et seq.
Date of Formation | September 15, 2025 (target date)
Formation Document | Certificate of Limited Partnership to be filed with the Delaware Secretary of State, Division of Corporations
Registered Agent | Capitol Registered Agents Inc., 850 New Burton Road, Suite 201, Dover, DE 19904
General Partner | Solara Consolidated Master Fund GP LLC, a Delaware limited liability company
Principal Office | 1200 Market Street, Suite 3400, Wilmington, DE 19801
EIN | Applied for (Form SS-4 to be filed concurrently with entity formation)
Fiscal Year | Calendar year (December 31 year-end)
Initial Tax Year | Short period from September 15, 2025 through December 31, 2025
Category | Amount
Total fair market value of assets to be contributed | $7.75 billion
Total adjusted tax basis of assets to be contributed | $6.03 billion
Total built-in gain | $1.72 billion
Aggregate liabilities to be assumed by the Master Fund | $1.34 billion
Role | Name | Office | Contact
Responsible Partner | Leonard Cross | Calderwood & Harkness LLP, Washington, D.C. | (202) 555-0231
Working Associate | Garrett Simmons | Calderwood & Harkness LLP, New York | (212) 555-0417
Of Counsel (Review) | Sylvia Hartwell | Calderwood & Harkness LLP, New York | (212) 555-0394

FORM 8832

CONSENT STATEMENT AND SIGNATURES

FILING INSTRUCTIONS AND COVER NOTES

Record

Parties

Dates

Amounts