1041-00005 · Client 1041 · Entity Formation

form-8832-tax-exempt-feeder.docx DOCUMENT M&A / Corporate

22 / 86 ← → ✕

FORM 8832

Entity Classification Election

Department of the Treasury Internal Revenue Service

Under Treasury Regulation § 301.7701-3

OMB No. 1545-1516

Note: This is a completed Form 8832, prepared in connection with the formation of Solara Tax-Exempt Feeder (Cayman) LP, a Cayman Islands exempted limited partnership. All fields have been populated in accordance with the instructions to Form 8832 (Rev. January 2012) and the applicable Treasury Regulations. A supplemental statement providing additional information regarding the eligible entity and the broader reorganization is attached hereto and incorporated by reference. This document constitutes attorney work product of Calderwood & Harkness LLP prepared in connection with Engagement No. 20250527-SDILP-PLR. A copy of this election will be attached to the entity's initial U.S. federal income tax return (Form 1065).

PART I — ELECTION INFORMATION

Line 1 — Type of Election

Initial classification by a newly formed entity.

Change in current classification.

The electing entity is a newly formed Cayman Islands exempted limited partnership that has not yet filed a U.S. federal tax return for any prior taxable period. No prior entity classification election under Treasury Regulation § 301.7701-3 has been filed with respect to this entity. This election constitutes the entity's initial classification election for U.S. federal income tax purposes. Because the entity has not previously been in existence for U.S. tax purposes, there is no prior default classification that is being changed; rather, this election establishes the entity's classification effective as of its date of formation.

Line 2a — Name of Eligible Entity Making Election

Solara Tax-Exempt Feeder (Cayman) LP

Line 2b — Employer Identification Number (EIN)

EIN: To be applied for

An application for an Employer Identification Number on Form SS-4 (Application for Employer Identification Number) is pending. The entity's EIN has not yet been assigned by the Internal Revenue Service, as the entity is to be formed on or about September 15, 2025. The Form SS-4 application will be submitted to the Internal Revenue Service simultaneously with or prior to the filing of this Form 8832. Upon receipt of the assigned EIN, a copy of this Form 8832 will be updated to reflect the EIN and retained in the engagement file.

Supplemental Note: The entity's formation is targeted for September 15, 2025. The EIN application will reference the entity's Cayman Islands registered office address and its U.S. mailing address for tax correspondence. Upon assignment of the EIN, the responsible attorney (Leonard Cross, Calderwood & Harkness LLP) will annotate this form and ensure that the assigned EIN is reflected on all related filings, including the companion Forms 8832 and the private letter ruling request.

Line 3 — Address of Eligible Entity

Registered Office Address (Cayman Islands):

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

Principal U.S. Mailing Address for Tax Correspondence:

c/o Solara Digital Infrastructure LP 1200 Market Street, Suite 3400 Wilmington, DE 19801 United States

The address listed above as the registered office is the Cayman Islands registered office of the entity, maintained through Harborstone Corporate Services Ltd., the entity's registered agent in the Cayman Islands. For purposes of all U.S. federal tax correspondence, including correspondence relating to this Form 8832, the entity's principal U.S. mailing address is the Wilmington, Delaware address of Solara Digital Infrastructure LP, the controlling sponsor entity. All IRS correspondence should be directed to the U.S. mailing address unless otherwise instructed.

Line 4 — Type of 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 electing to be classified as a disregarded entity.

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 electing to be classified as a disregarded entity.

The electing entity is organized as an exempted limited partnership under the Exempted Limited Partnership Act (As Revised) of the Cayman Islands. Because the entity is organized under the laws of a jurisdiction outside the United States—namely, the Cayman Islands—it is classified as a "foreign" entity for U.S. federal income tax purposes within the meaning of Treasury Regulation § 301.7701-5.

The entity is an "eligible entity" within the meaning of Treasury Regulation § 301.7701-3(a) because it is a business entity that is not classified as a corporation under Treasury Regulation § 301.7701-2(b). Specifically, a Cayman Islands exempted limited partnership is not included on the list of per se corporations set forth in Treasury Regulation § 301.7701-2(b)(8). That regulation enumerates specific foreign entities that are treated as per se corporations for U.S. federal income tax purposes. The Cayman Islands entries on the per se corporation list are limited to entities formed under specific Cayman Islands statutes that do not include the Exempted Limited Partnership Act. Accordingly, the entity qualifies as an eligible entity that may affirmatively elect its classification for U.S. federal income tax purposes.

Line 5 — Election

Elected Classification: Partnership

The entity hereby elects to be classified as a partnership for U.S. federal income tax purposes under Treasury Regulation § 301.7701-3(c). This election is made on behalf of the entity and with the consent of all of its members, as further described in the Consent Statement below and in the attached Supplemental Statement.

It is noted that under the default classification rules of Treasury Regulation § 301.7701-3(b)(2)(i), a foreign eligible entity with two or more members is classified as either (A) a partnership, if at least one member does not have limited liability, or (B) an association taxable as a corporation, if all members have limited liability. Because the entity is a limited partnership with a general partner that has unlimited liability for the obligations of the partnership under Cayman Islands law, the entity may default to partnership classification under the foregoing rule. Notwithstanding the potential applicability of this default classification, this affirmative election is being filed to (i) confirm partnership classification with certainty, (ii) establish a definite effective date coordinated with the broader reorganization timeline, and (iii) provide documentary support for the partnership classification representations made in the pending private letter ruling request to the Internal Revenue Service.

Line 6 — Effective Date of Election

Effective Date: September 15, 2025

The requested effective date of this election is September 15, 2025. This date has been selected to coincide with the target formation date of the entity under Cayman Islands law. On this same date, two companion entities—Solara Consolidated Master Fund GP LLC (a Delaware limited liability company) and Solara Consolidated Master Fund LP (a Delaware limited partnership)—are also being formed in connection with the broader cross-border fund-platform reorganization undertaken by Solara Digital Infrastructure LP.

The effective date of September 15, 2025 falls within the permissible window for initial classification elections under Treasury Regulation § 301.7701-3(c)(1)(iii). Under that regulation, an eligible entity may file an initial classification election that is effective on the date of the entity's formation, provided the election is filed within 75 days after the formation date. Because this election is being filed no earlier than 75 days before, and no later than 75 days after, the September 15, 2025 effective date, the election is timely.

The selection of September 15, 2025 as the effective date is critical to the sequencing of the multi-step reorganization. The reorganization contemplates the following timeline:

• Step 1 (September 15, 2025): Formation of new entities, including Solara Tax-Exempt Feeder (Cayman) LP, Solara Consolidated Master Fund LP, and Solara International Feeder (Cayman) LP.

• Step 2 (October 1, 2025): Contribution of portfolio assets from legacy Fund IV vehicles into the Consolidated Master Fund LP.

• Step 3 (October 15, 2025): Contribution of portfolio assets from legacy Fund V vehicles into the Consolidated Master Fund LP.

• Step 4 (November 1, 2025): Dissolution of legacy offshore fund vehicles and distribution of Consolidated Master Fund LP interests to continuing limited partners.

• Step 5 (December 1, 2025): Migration of U.S. tax-exempt limited partners from legacy Cayman parallel vehicles into Solara Tax-Exempt Feeder (Cayman) LP, which will hold a limited partnership interest in the Consolidated Master Fund LP.

By establishing partnership classification effective September 15, 2025, this election ensures that the entity is properly classified as a partnership for U.S. federal income tax purposes before the Tax-Exempt Feeder receives LP interests in the Consolidated Master Fund during Step 5 of the reorganization.

Line 7 — Was the Eligible Entity Previously Classified Differently for Federal Tax Purposes?

No.

Yes. (If "Yes," provide the previous classification and the date of the previous election or default classification.)

This is a newly formed entity with no prior classification history for U.S. federal income tax purposes. The entity has never filed a U.S. federal tax return, has never been classified as a corporation or as a disregarded entity, and has not previously made an election under Treasury Regulation § 301.7701-3. Accordingly, the sixty-month limitation on re-elections under Treasury Regulation § 301.7701-3(c)(1)(iv) does not apply.

Line 8 — Consent Statement and Authorized Person

Each member of the electing entity must consent to the entity classification election. Because the entity is newly formed and has not yet admitted its initial limited partners as of the date this Form 8832 is being prepared, the consent of the initial members is given through the authorized person signing this form on behalf of the entity and its members.

The authorized person signing this form is Viktor Raines, Managing Partner of Solara Digital Infrastructure GP LLC, which serves as the ultimate controlling entity of the general partner of Solara Tax-Exempt Feeder (Cayman) LP. Mr. Raines is authorized to execute this election on behalf of the entity and to bind the entity and its members to the election.

The consent of each limited partner that is subsequently admitted to the entity will be documented in such limited partner's subscription agreement and joinder to the limited partnership agreement of Solara Tax-Exempt Feeder (Cayman) LP, which will include an acknowledgment that this entity classification election has been filed and that the limited partner consents to the entity's classification as a partnership for U.S. federal income tax purposes.

PART II — LATE ELECTION RELIEF

This Part is Not Applicable.

Part II of Form 8832 provides for late election relief under Revenue Procedure 2009-41 and related guidance for eligible entities that fail to timely file an initial classification election or a change in classification election. Because the election set forth in Part I above is being filed on a timely basis—either concurrent with or prior to the entity's initial U.S. federal tax return and within the 75-day window prescribed by Treasury Regulation § 301.7701-3(c)(1)(iii)—no late election relief is required. All fields in Part II are left blank.

CONSENT STATEMENT AND SIGNATURE BLOCK

Consent Statement

Under penalties of perjury, I declare that I am authorized to make this election on behalf of the above-named entity and that I have examined this election, including any accompanying statements and schedules, and to the best of my knowledge and belief, it is true, correct, and complete. I further declare that I consent to the election to classify the above-named entity as a partnership for U.S. federal income tax purposes, effective September 15, 2025, and that I am authorized to provide such consent on behalf of the entity and each of its current and initial members.

Authorized Signer:

Name: Viktor Raines

Title: Managing Partner, Solara Digital Infrastructure GP LLC (EIN 82-4917365), in its capacity as the ultimate controlling entity of the general partner of Solara Tax-Exempt Feeder (Cayman) LP

Signature: ________

Date: ________

(To be executed on or about September 15, 2025)

Contact Information for Further Communication

Contact Person: Leonard Cross Title: Responsible Partner, Tax Firm: Calderwood & Harkness LLP Address: 1900 K Street NW, Suite 1100, Washington, DC 20006 Telephone: [To be inserted] Email: [To be inserted]

A Power of Attorney (Form 2848, Power of Attorney and Declaration of Representative) designating Leonard Cross and Sylvia Hartwell of Calderwood & Harkness LLP as authorized representatives of Solara Tax-Exempt Feeder (Cayman) LP before the Internal Revenue Service has been or will be filed in connection with this matter. The Power of Attorney relates to Calderwood & Harkness LLP Engagement No. 20250527-SDILP-PLR and covers, among other matters, entity classification elections, the pending private letter ruling request, and the entity's U.S. federal income tax returns.

ATTACHMENT — SUPPLEMENTAL STATEMENT

Solara Tax-Exempt Feeder (Cayman) LP Form 8832 — Entity Classification Election Effective Date: September 15, 2025

This Supplemental Statement is attached to and filed as part of Form 8832, Entity Classification Election, filed on behalf of Solara Tax-Exempt Feeder (Cayman) LP (the "Entity"). This statement provides additional information regarding the Entity, its structure, its relationship to a broader cross-border fund-platform reorganization, and confirmation of the Entity's status as an "eligible entity" under Treasury Regulation § 301.7701-3(a).

I. Description of the Eligible Entity

Full Legal Name: Solara Tax-Exempt Feeder (Cayman) LP

Entity Type: Cayman Islands exempted limited partnership, formed under the Exempted Limited Partnership Act (As Revised) of the Cayman Islands.

Jurisdiction of Organization: Cayman Islands

Date of Formation: Target date September 15, 2025. As of the date of preparation of this Form 8832, the Entity has not yet been formed. Formation will be completed upon registration of the exempted limited partnership with the Registrar of Exempted Limited Partnerships of the Cayman Islands on or about September 15, 2025, in accordance with the Exempted Limited Partnership Act.

Registered Office:

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

Harborstone Corporate Services Ltd. serves as the registered agent and provides registered office services for the Entity in the Cayman Islands.

Cayman Islands Counsel:

Meridian Offshore Legal

Attn: Fiona McAllister, Partner

Caledonia House 69 Dr. Roy's Drive George Town, Grand Cayman KY1-1103 Cayman Islands

Meridian Offshore Legal is acting as Cayman Islands counsel to the Entity and its sponsors in connection with the formation of the Entity and the related reorganization transactions.

Purpose of the Entity: The Entity is being formed as a feeder vehicle for U.S. tax-exempt investors—including, without limitation, pension funds such as Pinnacle State Employees' Retirement System and endowments such as Grandview University Endowment—to invest into Solara Consolidated Master Fund LP, a Delaware limited partnership that is also being formed in connection with the reorganization and that is also electing partnership classification on a companion Form 8832 with the same effective date. The feeder structure is specifically designed to mitigate unrelated business taxable income ("UBTI") concerns for U.S. tax-exempt limited partners under Sections 511 through 514 of the Internal Revenue Code. By investing through a Cayman Islands exempted limited partnership that holds a single limited partnership interest in the Consolidated Master Fund, the tax-exempt investors are intended to be shielded from direct allocations of income that might constitute UBTI, including income from debt-financed property and income from the conduct of an unrelated trade or business. The Entity is not expected to engage in any trade or business activity directly; rather, it will serve solely as an intermediate holding vehicle through which tax-exempt investors participate in the investment program of the Consolidated Master Fund.

Number of Members: The Entity will have at least two members: (a) a general partner entity (which will be an entity controlled by Solara Digital Infrastructure GP LLC, EIN 82-4917365, a Delaware limited liability company managed by Viktor Raines), and (b) one or more limited partners, consisting of U.S. tax-exempt institutional investors. Because the Entity will have at least two members at all relevant times, classification as a disregarded entity is not available, and the appropriate elective classification is as a partnership.

General Partner: The general partner of the Entity will be an entity controlled by Solara Digital Infrastructure GP LLC (EIN 82-4917365), a Delaware limited liability company. Solara Digital Infrastructure GP LLC is managed by Viktor Raines, who serves as Managing Partner. The general partner of the Entity will have unlimited liability for the obligations and liabilities of the Entity under the Exempted Limited Partnership Act and the Entity's limited partnership agreement. This unlimited liability feature is relevant to the default classification analysis under Treasury Regulation § 301.7701-3(b)(2)(i), as discussed in Section III below.

II. Relationship to Broader Reorganization

This Form 8832 is one of three entity classification elections being filed in connection with a cross-border fund-platform reorganization (the "Reorganization") undertaken by Solara Digital Infrastructure LP (EIN 82-4917366), a Delaware limited partnership that serves as the primary private equity sponsor platform. As of March 31, 2025, Solara Digital Infrastructure LP had approximately $14.7 billion in assets under management across multiple fund vehicles.

Companion Form 8832 Elections. In addition to this election on behalf of Solara Tax-Exempt Feeder (Cayman) LP, companion Form 8832 elections are being filed contemporaneously for the following entities, each of which is electing partnership classification effective September 15, 2025:

1. Solara Consolidated Master Fund LP — A Delaware limited partnership being formed to serve as the master fund vehicle into which portfolio assets from the legacy fund vehicles will be contributed. As a domestic eligible entity with two or more members, Solara Consolidated Master Fund LP is filing a Form 8832 election to confirm its classification as a partnership for U.S. federal income tax purposes.

2. Solara International Feeder (Cayman) LP — A Cayman Islands exempted limited partnership being formed to serve as a feeder vehicle for non-U.S. investors (i.e., investors that are not U.S. persons within the meaning of Section 7701(a)(30) of the Internal Revenue Code). As a foreign eligible entity with two or more members, Solara International Feeder (Cayman) LP is filing a Form 8832 election to confirm its classification as a partnership for U.S. federal income tax purposes.

Overview of the Reorganization. The Reorganization involves the consolidation of four legacy offshore fund vehicles into a single master-fund/feeder structure. The legacy vehicles are:

• Fund IV-A (Cayman) LP (EIN 98-6241503) — A Cayman Islands exempted limited partnership.

• Fund IV-B (Luxembourg) SCSp (EIN 98-6241571) — A Luxembourg special limited partnership (société en commandite spéciale).

• Fund V-A (Cayman) LP (EIN 98-7891234) — A Cayman Islands exempted limited partnership.

• Fund V-B (Luxembourg) SCSp (EIN 98-7891267) — A Luxembourg special limited partnership (société en commandite spéciale).

The Reorganization contemplates the contribution of portfolio assets from these four legacy fund vehicles into Solara Consolidated Master Fund LP, followed by the dissolution of the legacy vehicles and the migration of limited partners into the new feeder structure. The Reorganization is being implemented in a series of sequential steps, as follows:

Step 1 (September 15, 2025): Formation of Solara Tax-Exempt Feeder (Cayman) LP, Solara International Feeder (Cayman) LP, Solara Consolidated Master Fund LP, and Solara Consolidated Master Fund GP LLC. Filing of Forms 8832 and SS-4 for each newly formed entity.

Step 2 (October 1, 2025): Contribution by Fund IV-A (Cayman) LP and Fund IV-B (Luxembourg) SCSp of their respective portfolio assets (consisting principally of interests in digital infrastructure operating companies, data center joint ventures, and fiber network assets) to Solara Consolidated Master Fund LP in exchange for limited partnership interests therein. These contributions are intended to qualify as tax-free contributions under Section 721(a) of the Internal Revenue Code.

Step 3 (October 15, 2025): Contribution by Fund V-A (Cayman) LP and Fund V-B (Luxembourg) SCSp of their respective portfolio assets to Solara Consolidated Master Fund LP in exchange for limited partnership interests therein, similarly intended to qualify under Section 721(a).

Step 4 (November 1, 2025): Dissolution of the four legacy fund vehicles and distribution of Solara Consolidated Master Fund LP interests to the continuing limited partners of the legacy vehicles. These distributions are intended to qualify as tax-free distributions under Section 731(a) of the Internal Revenue Code to the extent that no money or marketable securities in excess of the distributee partner's basis are distributed.

Step 5 (December 1, 2025): Migration of limited partners into the new feeder structure. U.S. tax-exempt limited partners currently invested in the legacy Cayman parallel vehicles will contribute their Consolidated Master Fund LP interests (received in Step 4) to Solara Tax-Exempt Feeder (Cayman) LP in exchange for limited partnership interests in the Tax-Exempt Feeder. Non-U.S. limited partners will similarly contribute their interests to Solara International Feeder (Cayman) LP. Following the completion of Step 5, each feeder will hold a limited partnership interest in the Consolidated Master Fund, and the limited partners will hold interests in the appropriate feeder vehicle.

Private Letter Ruling Request. A private letter ruling request is being submitted to the Internal Revenue Service, Office of the Associate Chief Counsel (International) (CC:INTL), with secondary jurisdiction in the Office of the Associate Chief Counsel (Passthroughs & Special Industries) (CC:PSI), on or about August 15, 2025. The ruling request seeks confirmation of the U.S. federal income tax treatment of the multi-step Reorganization, including:

(a) Confirmation that the contributions of portfolio assets in Steps 2 and 3 qualify as tax-free contributions to a partnership under Section 721(a) of the Internal Revenue Code;

(b) Confirmation that the distributions in Step 4 qualify as tax-free distributions from a partnership under Section 731(a) of the Internal Revenue Code;

(d) Confirmation that no gain or loss is recognized by any limited partner as a result of the multi-step Reorganization, taken as a whole; and

(e) Confirmation that each of the three newly formed entities—including Solara Tax-Exempt Feeder (Cayman) LP—is properly classified as a partnership under Treasury Regulation § 301.7701-3 (Ruling 8 of the PLR request).

The ruling request is being prepared and submitted by Calderwood & Harkness LLP under Engagement No. 20250527-SDILP-PLR, with Leonard Cross serving as Responsible Partner, Tax, and Robert Jansen serving as Lead Associate, Tax.

III. Confirmation of Eligible Entity Status

A Cayman Islands exempted limited partnership is not included on the list of per se corporations set forth in Treasury Regulation § 301.7701-2(b)(8). The per se corporation list enumerates specific types of foreign entities, organized by jurisdiction, that are automatically classified as corporations for U.S. federal income tax purposes without regard to the entity's characteristics or the election provisions of Treasury Regulation § 301.7701-3. For the Cayman Islands, the per se corporation list includes only entities formed under certain Cayman Islands statutes (specifically, companies formed under the Companies Act), and does not include entities formed under the Exempted Limited Partnership Act.

Accordingly, the Entity is an "eligible entity" within the meaning of Treasury Regulation § 301.7701-3(a) and is permitted to elect its classification for U.S. federal income tax purposes by filing this Form 8832. The Entity has two or more members and therefore may elect to be classified as either (i) a partnership or (ii) an association taxable as a corporation. The Entity elects to be classified as a partnership, effective September 15, 2025.

This election is consistent with the representations made in the pending private letter ruling request to the Internal Revenue Service. Specifically, Ruling 8 of the PLR request asks the IRS to confirm that each of the three newly formed entities—Solara Tax-Exempt Feeder (Cayman) LP, Solara International Feeder (Cayman) LP, and Solara Consolidated Master Fund LP—is properly classified as a partnership for U.S. federal income tax purposes under Treasury Regulation § 301.7701-3. The filing of this Form 8832 election is a predicate step in establishing the partnership classification that is assumed and relied upon throughout the multi-step Reorganization.

FILING INSTRUCTIONS AND INTERNAL NOTES

Calderwood & Harkness LLP — Attorney Work Product Engagement No. 20250527-SDILP-PLR

PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT — NOT FOR FILING WITH THE IRS The following filing instructions and internal notes are prepared by Calderwood & Harkness LLP for the use of the engagement team and the client. This page is not part of the Form 8832 submission and should be removed prior to filing.

Filing Address:

This completed Form 8832, together with the attached Supplemental Statement, is to be filed with:

Internal Revenue Service Center Ogden, UT 84201

This is the designated service center for entities that do not yet have an existing EIN. If the entity's EIN is obtained prior to filing, the form may alternatively be filed with the service center where the entity's annual income tax return (Form 1065) will be filed, which is expected to be the Ogden, UT service center in any event.

Timing:

The election must be filed no earlier than 75 days before the requested effective date and no later than 75 days after the requested effective date.

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

• Latest permissible filing date: November 29, 2025 (75 days after September 15, 2025)

• Target filing date: On or about September 15, 2025, concurrent with entity formation.

Coordination with Form SS-4:

This Form 8832 should be filed in coordination with the Form SS-4 (Application for Employer Identification Number) for the Entity. The EIN should be obtained prior to or concurrently with the filing of this Form 8832. If the EIN is obtained prior to filing, the EIN should be entered on Line 2b before submission. If the Form 8832 is filed before the EIN is assigned, the form should note "Applied for" on Line 2b, and a supplemental notification should be sent to the IRS upon receipt of the assigned EIN.

Coordination with Companion Elections:

This Form 8832 is being filed simultaneously with companion Form 8832 elections for Solara Consolidated Master Fund LP and Solara International Feeder (Cayman) LP. All three elections should be filed on or about the same date, with the same effective date of September 15, 2025. The filing of all three elections should be confirmed and documented in the engagement team's tracking system.

Engagement Team:

Document Retention:

• A copy of this Form 8832 election (as filed) is to be retained in the PLR submission file and cross-referenced in the Closing Checklist — PLR Submission.

• A copy of this election will be attached to the Entity's first U.S. federal income tax return (Form 1065) for the taxable year that includes September 15, 2025, as required by Treasury Regulation § 301.7701-3(c)(1)(i).

• The original signed Form 8832 will be sent to the IRS via certified mail, return receipt requested, or via a designated private delivery service approved under Section 7502(f) of the Internal Revenue Code. Proof of mailing and the return receipt (or equivalent delivery confirmation) are to be retained in the engagement file.

• An electronic copy (PDF) of the signed form and all attachments is to be maintained in the Calderwood & Harkness document management system under Engagement No. 20250527-SDILP-PLR.

End of Form 8832 and Supplemental Statement — Solara Tax-Exempt Feeder (Cayman) LP Prepared by Calderwood & Harkness LLP — Draft dated [________], 2025

Role	Name	Firm
Responsible Partner, Tax	Leonard Cross	Calderwood & Harkness LLP
Lead Associate, Tax	Robert Jansen	Calderwood & Harkness LLP
Authorized Representative (Form 2848)	Leonard Cross	Calderwood & Harkness LLP
Authorized Representative (Form 2848)	Sylvia Hartwell	Calderwood & Harkness LLP

FORM 8832
Entity Classification Election
Department of the Treasury Internal Revenue Service
Under Treasury Regulation § 301.7701-3
OMB No. 1545-1516
Note: This is a completed Form 8832, prepared in connection with the formation of Solara Tax-Exempt Feeder (Cayman) LP, a Cayman Islands exempted limited partnership. All fields have been populated in accordance with the instructions to Form 8832 (Rev. January 2012) and the applicable Treasury Regulations. A supplemental statement providing additional information regarding the eligible entity and the broader reorganization is attached hereto and incorporated by reference. This document constitutes attorney work product of Calderwood & Harkness LLP prepared in connection with Engagement No. 20250527-SDILP-PLR. A copy of this election will be attached to the entity's initial U.S. federal income tax return (Form 1065).
PART I — ELECTION INFORMATION
Line 1 — Type of Election
Initial classification by a newly formed entity.
Change in current classification.
The electing entity is a newly formed Cayman Islands exempted limited partnership that has not yet filed a U.S. federal tax return for any prior taxable period. No prior entity classification election under Treasury Regulation § 301.7701-3 has been filed with respect to this entity. This election constitutes the entity's initial classification election for U.S. federal income tax purposes. Because the entity has not previously been in existence for U.S. tax purposes, there is no prior default classification that is being changed; rather, this election establishes the entity's classification effective as of its date of formation.
Line 2a — Name of Eligible Entity Making Election
Solara Tax-Exempt Feeder (Cayman) LP
Line 2b — Employer Identification Number (EIN)
EIN: To be applied for
An application for an Employer Identification Number on Form SS-4 (Application for Employer Identification Number) is pending. The entity's EIN has not yet been assigned by the Internal Revenue Service, as the entity is to be formed on or about September 15, 2025. The Form SS-4 application will be submitted to the Internal Revenue Service simultaneously with or prior to the filing of this Form 8832. Upon receipt of the assigned EIN, a copy of this Form 8832 will be updated to reflect the EIN and retained in the engagement file.
Supplemental Note: The entity's formation is targeted for September 15, 2025. The EIN application will reference the entity's Cayman Islands registered office address and its U.S. mailing address for tax correspondence. Upon assignment of the EIN, the responsible attorney (Leonard Cross, Calderwood & Harkness LLP) will annotate this form and ensure that the assigned EIN is reflected on all related filings, including the companion Forms 8832 and the private letter ruling request.
Line 3 — Address of Eligible Entity
Registered Office Address (Cayman Islands):
c/o Harborstone Corporate Services Ltd. P.O. Box 2714 94 Solaris Avenue George Town, Grand Cayman KY1-1111 Cayman Islands
Principal U.S. Mailing Address for Tax Correspondence:
c/o Solara Digital Infrastructure LP 1200 Market Street, Suite 3400 Wilmington, DE 19801 United States
The address listed above as the registered office is the Cayman Islands registered office of the entity, maintained through Harborstone Corporate Services Ltd., the entity's registered agent in the Cayman Islands. For purposes of all U.S. federal tax correspondence, including correspondence relating to this Form 8832, the entity's principal U.S. mailing address is the Wilmington, Delaware address of Solara Digital Infrastructure LP, the controlling sponsor entity. All IRS correspondence should be directed to the U.S. mailing address unless otherwise instructed.
Line 4 — Type of 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 electing to be classified as a disregarded entity.
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 electing to be classified as a disregarded entity.
The electing entity is organized as an exempted limited partnership under the Exempted Limited Partnership Act (As Revised) of the Cayman Islands. Because the entity is organized under the laws of a jurisdiction outside the United States—namely, the Cayman Islands—it is classified as a "foreign" entity for U.S. federal income tax purposes within the meaning of Treasury Regulation § 301.7701-5.
The entity is an "eligible entity" within the meaning of Treasury Regulation § 301.7701-3(a) because it is a business entity that is not classified as a corporation under Treasury Regulation § 301.7701-2(b). Specifically, a Cayman Islands exempted limited partnership is not included on the list of per se corporations set forth in Treasury Regulation § 301.7701-2(b)(8). That regulation enumerates specific foreign entities that are treated as per se corporations for U.S. federal income tax purposes. The Cayman Islands entries on the per se corporation list are limited to entities formed under specific Cayman Islands statutes that do not include the Exempted Limited Partnership Act. Accordingly, the entity qualifies as an eligible entity that may affirmatively elect its classification for U.S. federal income tax purposes.
Line 5 — Election
Elected Classification: Partnership
The entity hereby elects to be classified as a partnership for U.S. federal income tax purposes under Treasury Regulation § 301.7701-3(c). This election is made on behalf of the entity and with the consent of all of its members, as further described in the Consent Statement below and in the attached Supplemental Statement.
It is noted that under the default classification rules of Treasury Regulation § 301.7701-3(b)(2)(i), a foreign eligible entity with two or more members is classified as either (A) a partnership, if at least one member does not have limited liability, or (B) an association taxable as a corporation, if all members have limited liability. Because the entity is a limited partnership with a general partner that has unlimited liability for the obligations of the partnership under Cayman Islands law, the entity may default to partnership classification under the foregoing rule. Notwithstanding the potential applicability of this default classification, this affirmative election is being filed to (i) confirm partnership classification with certainty, (ii) establish a definite effective date coordinated with the broader reorganization timeline, and (iii) provide documentary support for the partnership classification representations made in the pending private letter ruling request to the Internal Revenue Service.
Line 6 — Effective Date of Election
Effective Date: September 15, 2025
The requested effective date of this election is September 15, 2025. This date has been selected to coincide with the target formation date of the entity under Cayman Islands law. On this same date, two companion entities—Solara Consolidated Master Fund GP LLC (a Delaware limited liability company) and Solara Consolidated Master Fund LP (a Delaware limited partnership)—are also being formed in connection with the broader cross-border fund-platform reorganization undertaken by Solara Digital Infrastructure LP.
The effective date of September 15, 2025 falls within the permissible window for initial classification elections under Treasury Regulation § 301.7701-3(c)(1)(iii). Under that regulation, an eligible entity may file an initial classification election that is effective on the date of the entity's formation, provided the election is filed within 75 days after the formation date. Because this election is being filed no earlier than 75 days before, and no later than 75 days after, the September 15, 2025 effective date, the election is timely.
The selection of September 15, 2025 as the effective date is critical to the sequencing of the multi-step reorganization. The reorganization contemplates the following timeline:
•  Step 1 (September 15, 2025): Formation of new entities, including Solara Tax-Exempt Feeder (Cayman) LP, Solara Consolidated Master Fund LP, and Solara International Feeder (Cayman) LP.
•  Step 2 (October 1, 2025): Contribution of portfolio assets from legacy Fund IV vehicles into the Consolidated Master Fund LP.
•  Step 3 (October 15, 2025): Contribution of portfolio assets from legacy Fund V vehicles into the Consolidated Master Fund LP.
•  Step 4 (November 1, 2025): Dissolution of legacy offshore fund vehicles and distribution of Consolidated Master Fund LP interests to continuing limited partners.
•  Step 5 (December 1, 2025): Migration of U.S. tax-exempt limited partners from legacy Cayman parallel vehicles into Solara Tax-Exempt Feeder (Cayman) LP, which will hold a limited partnership interest in the Consolidated Master Fund LP.
By establishing partnership classification effective September 15, 2025, this election ensures that the entity is properly classified as a partnership for U.S. federal income tax purposes before the Tax-Exempt Feeder receives LP interests in the Consolidated Master Fund during Step 5 of the reorganization.
Line 7 — Was the Eligible Entity Previously Classified Differently for Federal Tax Purposes?
No.
Yes. (If "Yes," provide the previous classification and the date of the previous election or default classification.)
This is a newly formed entity with no prior classification history for U.S. federal income tax purposes. The entity has never filed a U.S. federal tax return, has never been classified as a corporation or as a disregarded entity, and has not previously made an election under Treasury Regulation § 301.7701-3. Accordingly, the sixty-month limitation on re-elections under Treasury Regulation § 301.7701-3(c)(1)(iv) does not apply.
Line 8 — Consent Statement and Authorized Person
Each member of the electing entity must consent to the entity classification election. Because the entity is newly formed and has not yet admitted its initial limited partners as of the date this Form 8832 is being prepared, the consent of the initial members is given through the authorized person signing this form on behalf of the entity and its members.
The authorized person signing this form is Viktor Raines, Managing Partner of Solara Digital Infrastructure GP LLC, which serves as the ultimate controlling entity of the general partner of Solara Tax-Exempt Feeder (Cayman) LP. Mr. Raines is authorized to execute this election on behalf of the entity and to bind the entity and its members to the election.
The consent of each limited partner that is subsequently admitted to the entity will be documented in such limited partner's subscription agreement and joinder to the limited partnership agreement of Solara Tax-Exempt Feeder (Cayman) LP, which will include an acknowledgment that this entity classification election has been filed and that the limited partner consents to the entity's classification as a partnership for U.S. federal income tax purposes.
PART II — LATE ELECTION RELIEF
This Part is Not Applicable.
Part II of Form 8832 provides for late election relief under Revenue Procedure 2009-41 and related guidance for eligible entities that fail to timely file an initial classification election or a change in classification election. Because the election set forth in Part I above is being filed on a timely basis—either concurrent with or prior to the entity's initial U.S. federal tax return and within the 75-day window prescribed by Treasury Regulation § 301.7701-3(c)(1)(iii)—no late election relief is required. All fields in Part II are left blank.
CONSENT STATEMENT AND SIGNATURE BLOCK
Consent Statement
Under penalties of perjury, I declare that I am authorized to make this election on behalf of the above-named entity and that I have examined this election, including any accompanying statements and schedules, and to the best of my knowledge and belief, it is true, correct, and complete. I further declare that I consent to the election to classify the above-named entity as a partnership for U.S. federal income tax purposes, effective September 15, 2025, and that I am authorized to provide such consent on behalf of the entity and each of its current and initial members.
Authorized Signer:
Name: Viktor Raines
Title: Managing Partner, Solara Digital Infrastructure GP LLC (EIN 82-4917365), in its capacity as the ultimate controlling entity of the general partner of Solara Tax-Exempt Feeder (Cayman) LP
Signature: ________
Date: ________
(To be executed on or about September 15, 2025)
Contact Information for Further Communication
Contact Person: Leonard Cross Title: Responsible Partner, Tax Firm: Calderwood & Harkness LLP Address: 1900 K Street NW, Suite 1100, Washington, DC 20006 Telephone: [To be inserted] Email: [To be inserted]
A Power of Attorney (Form 2848, Power of Attorney and Declaration of Representative) designating Leonard Cross and Sylvia Hartwell of Calderwood & Harkness LLP as authorized representatives of Solara Tax-Exempt Feeder (Cayman) LP before the Internal Revenue Service has been or will be filed in connection with this matter. The Power of Attorney relates to Calderwood & Harkness LLP Engagement No. 20250527-SDILP-PLR and covers, among other matters, entity classification elections, the pending private letter ruling request, and the entity's U.S. federal income tax returns.
ATTACHMENT — SUPPLEMENTAL STATEMENT
Solara Tax-Exempt Feeder (Cayman) LP Form 8832 — Entity Classification Election Effective Date: September 15, 2025
This Supplemental Statement is attached to and filed as part of Form 8832, Entity Classification Election, filed on behalf of Solara Tax-Exempt Feeder (Cayman) LP (the "Entity"). This statement provides additional information regarding the Entity, its structure, its relationship to a broader cross-border fund-platform reorganization, and confirmation of the Entity's status as an "eligible entity" under Treasury Regulation § 301.7701-3(a).
I. Description of the Eligible Entity
Full Legal Name: Solara Tax-Exempt Feeder (Cayman) LP
Entity Type: Cayman Islands exempted limited partnership, formed under the Exempted Limited Partnership Act (As Revised) of the Cayman Islands.
Jurisdiction of Organization: Cayman Islands
Date of Formation: Target date September 15, 2025. As of the date of preparation of this Form 8832, the Entity has not yet been formed. Formation will be completed upon registration of the exempted limited partnership with the Registrar of Exempted Limited Partnerships of the Cayman Islands on or about September 15, 2025, in accordance with the Exempted Limited Partnership Act.
Registered Office:
Harborstone Corporate Services Ltd. P.O. Box 2714 94 Solaris Avenue George Town, Grand Cayman KY1-1111 Cayman Islands
Harborstone Corporate Services Ltd. serves as the registered agent and provides registered office services for the Entity in the Cayman Islands.
Cayman Islands Counsel:
Meridian Offshore Legal
Attn: Fiona McAllister, Partner
Caledonia House 69 Dr. Roy's Drive George Town, Grand Cayman KY1-1103 Cayman Islands
Meridian Offshore Legal is acting as Cayman Islands counsel to the Entity and its sponsors in connection with the formation of the Entity and the related reorganization transactions.
Purpose of the Entity: The Entity is being formed as a feeder vehicle for U.S. tax-exempt investors—including, without limitation, pension funds such as Pinnacle State Employees' Retirement System and endowments such as Grandview University Endowment—to invest into Solara Consolidated Master Fund LP, a Delaware limited partnership that is also being formed in connection with the reorganization and that is also electing partnership classification on a companion Form 8832 with the same effective date. The feeder structure is specifically designed to mitigate unrelated business taxable income ("UBTI") concerns for U.S. tax-exempt limited partners under Sections 511 through 514 of the Internal Revenue Code. By investing through a Cayman Islands exempted limited partnership that holds a single limited partnership interest in the Consolidated Master Fund, the tax-exempt investors are intended to be shielded from direct allocations of income that might constitute UBTI, including income from debt-financed property and income from the conduct of an unrelated trade or business. The Entity is not expected to engage in any trade or business activity directly; rather, it will serve solely as an intermediate holding vehicle through which tax-exempt investors participate in the investment program of the Consolidated Master Fund.
Number of Members: The Entity will have at least two members: (a) a general partner entity (which will be an entity controlled by Solara Digital Infrastructure GP LLC, EIN 82-4917365, a Delaware limited liability company managed by Viktor Raines), and (b) one or more limited partners, consisting of U.S. tax-exempt institutional investors. Because the Entity will have at least two members at all relevant times, classification as a disregarded entity is not available, and the appropriate elective classification is as a partnership.
General Partner: The general partner of the Entity will be an entity controlled by Solara Digital Infrastructure GP LLC (EIN 82-4917365), a Delaware limited liability company. Solara Digital Infrastructure GP LLC is managed by Viktor Raines, who serves as Managing Partner. The general partner of the Entity will have unlimited liability for the obligations and liabilities of the Entity under the Exempted Limited Partnership Act and the Entity's limited partnership agreement. This unlimited liability feature is relevant to the default classification analysis under Treasury Regulation § 301.7701-3(b)(2)(i), as discussed in Section III below.
II. Relationship to Broader Reorganization
This Form 8832 is one of three entity classification elections being filed in connection with a cross-border fund-platform reorganization (the "Reorganization") undertaken by Solara Digital Infrastructure LP (EIN 82-4917366), a Delaware limited partnership that serves as the primary private equity sponsor platform. As of March 31, 2025, Solara Digital Infrastructure LP had approximately $14.7 billion in assets under management across multiple fund vehicles.
Companion Form 8832 Elections. In addition to this election on behalf of Solara Tax-Exempt Feeder (Cayman) LP, companion Form 8832 elections are being filed contemporaneously for the following entities, each of which is electing partnership classification effective September 15, 2025:
1.  Solara Consolidated Master Fund LP — A Delaware limited partnership being formed to serve as the master fund vehicle into which portfolio assets from the legacy fund vehicles will be contributed. As a domestic eligible entity with two or more members, Solara Consolidated Master Fund LP is filing a Form 8832 election to confirm its classification as a partnership for U.S. federal income tax purposes.
2.  Solara International Feeder (Cayman) LP — A Cayman Islands exempted limited partnership being formed to serve as a feeder vehicle for non-U.S. investors (i.e., investors that are not U.S. persons within the meaning of Section 7701(a)(30) of the Internal Revenue Code). As a foreign eligible entity with two or more members, Solara International Feeder (Cayman) LP is filing a Form 8832 election to confirm its classification as a partnership for U.S. federal income tax purposes.
Overview of the Reorganization. The Reorganization involves the consolidation of four legacy offshore fund vehicles into a single master-fund/feeder structure. The legacy vehicles are:
•  Fund IV-A (Cayman) LP (EIN 98-6241503) — A Cayman Islands exempted limited partnership.
•  Fund IV-B (Luxembourg) SCSp (EIN 98-6241571) — A Luxembourg special limited partnership (société en commandite spéciale).
•  Fund V-A (Cayman) LP (EIN 98-7891234) — A Cayman Islands exempted limited partnership.
•  Fund V-B (Luxembourg) SCSp (EIN 98-7891267) — A Luxembourg special limited partnership (société en commandite spéciale).
The Reorganization contemplates the contribution of portfolio assets from these four legacy fund vehicles into Solara Consolidated Master Fund LP, followed by the dissolution of the legacy vehicles and the migration of limited partners into the new feeder structure. The Reorganization is being implemented in a series of sequential steps, as follows:
Step 1 (September 15, 2025): Formation of Solara Tax-Exempt Feeder (Cayman) LP, Solara International Feeder (Cayman) LP, Solara Consolidated Master Fund LP, and Solara Consolidated Master Fund GP LLC. Filing of Forms 8832 and SS-4 for each newly formed entity.
Step 2 (October 1, 2025): Contribution by Fund IV-A (Cayman) LP and Fund IV-B (Luxembourg) SCSp of their respective portfolio assets (consisting principally of interests in digital infrastructure operating companies, data center joint ventures, and fiber network assets) to Solara Consolidated Master Fund LP in exchange for limited partnership interests therein. These contributions are intended to qualify as tax-free contributions under Section 721(a) of the Internal Revenue Code.
Step 3 (October 15, 2025): Contribution by Fund V-A (Cayman) LP and Fund V-B (Luxembourg) SCSp of their respective portfolio assets to Solara Consolidated Master Fund LP in exchange for limited partnership interests therein, similarly intended to qualify under Section 721(a).
Step 4 (November 1, 2025): Dissolution of the four legacy fund vehicles and distribution of Solara Consolidated Master Fund LP interests to the continuing limited partners of the legacy vehicles. These distributions are intended to qualify as tax-free distributions under Section 731(a) of the Internal Revenue Code to the extent that no money or marketable securities in excess of the distributee partner's basis are distributed.
Step 5 (December 1, 2025): Migration of limited partners into the new feeder structure. U.S. tax-exempt limited partners currently invested in the legacy Cayman parallel vehicles will contribute their Consolidated Master Fund LP interests (received in Step 4) to Solara Tax-Exempt Feeder (Cayman) LP in exchange for limited partnership interests in the Tax-Exempt Feeder. Non-U.S. limited partners will similarly contribute their interests to Solara International Feeder (Cayman) LP. Following the completion of Step 5, each feeder will hold a limited partnership interest in the Consolidated Master Fund, and the limited partners will hold interests in the appropriate feeder vehicle.
Private Letter Ruling Request. A private letter ruling request is being submitted to the Internal Revenue Service, Office of the Associate Chief Counsel (International) (CC:INTL), with secondary jurisdiction in the Office of the Associate Chief Counsel (Passthroughs & Special Industries) (CC:PSI), on or about August 15, 2025. The ruling request seeks confirmation of the U.S. federal income tax treatment of the multi-step Reorganization, including:
(a) Confirmation that the contributions of portfolio assets in Steps 2 and 3 qualify as tax-free contributions to a partnership under Section 721(a) of the Internal Revenue Code;
(b) Confirmation that the distributions in Step 4 qualify as tax-free distributions from a partnership under Section 731(a) of the Internal Revenue Code;
(c) Confirmation that the contributions in Step 5 qualify as tax-free contributions under Section 721(a);
(d) Confirmation that no gain or loss is recognized by any limited partner as a result of the multi-step Reorganization, taken as a whole; and
(e) Confirmation that each of the three newly formed entities—including Solara Tax-Exempt Feeder (Cayman) LP—is properly classified as a partnership under Treasury Regulation § 301.7701-3 (Ruling 8 of the PLR request).
The ruling request is being prepared and submitted by Calderwood & Harkness LLP under Engagement No. 20250527-SDILP-PLR, with Leonard Cross serving as Responsible Partner, Tax, and Robert Jansen serving as Lead Associate, Tax.
III. Confirmation of Eligible Entity Status
A Cayman Islands exempted limited partnership is not included on the list of per se corporations set forth in Treasury Regulation § 301.7701-2(b)(8). The per se corporation list enumerates specific types of foreign entities, organized by jurisdiction, that are automatically classified as corporations for U.S. federal income tax purposes without regard to the entity's characteristics or the election provisions of Treasury Regulation § 301.7701-3. For the Cayman Islands, the per se corporation list includes only entities formed under certain Cayman Islands statutes (specifically, companies formed under the Companies Act), and does not include entities formed under the Exempted Limited Partnership Act.
Accordingly, the Entity is an "eligible entity" within the meaning of Treasury Regulation § 301.7701-3(a) and is permitted to elect its classification for U.S. federal income tax purposes by filing this Form 8832. The Entity has two or more members and therefore may elect to be classified as either (i) a partnership or (ii) an association taxable as a corporation. The Entity elects to be classified as a partnership, effective September 15, 2025.
This election is consistent with the representations made in the pending private letter ruling request to the Internal Revenue Service. Specifically, Ruling 8 of the PLR request asks the IRS to confirm that each of the three newly formed entities—Solara Tax-Exempt Feeder (Cayman) LP, Solara International Feeder (Cayman) LP, and Solara Consolidated Master Fund LP—is properly classified as a partnership for U.S. federal income tax purposes under Treasury Regulation § 301.7701-3. The filing of this Form 8832 election is a predicate step in establishing the partnership classification that is assumed and relied upon throughout the multi-step Reorganization.
FILING INSTRUCTIONS AND INTERNAL NOTES
Calderwood & Harkness LLP — Attorney Work Product Engagement No. 20250527-SDILP-PLR
PRIVILEGED AND CONFIDENTIAL — ATTORNEY WORK PRODUCT — NOT FOR FILING WITH THE IRS The following filing instructions and internal notes are prepared by Calderwood & Harkness LLP for the use of the engagement team and the client. This page is not part of the Form 8832 submission and should be removed prior to filing.
Filing Address:
This completed Form 8832, together with the attached Supplemental Statement, is to be filed with:
Internal Revenue Service Center Ogden, UT 84201
This is the designated service center for entities that do not yet have an existing EIN. If the entity's EIN is obtained prior to filing, the form may alternatively be filed with the service center where the entity's annual income tax return (Form 1065) will be filed, which is expected to be the Ogden, UT service center in any event.
Timing:
The election must be filed no earlier than 75 days before the requested effective date and no later than 75 days after the requested effective date.
•  Earliest permissible filing date: July 2, 2025 (75 days before September 15, 2025)
•  Latest permissible filing date: November 29, 2025 (75 days after September 15, 2025)
•  Target filing date: On or about September 15, 2025, concurrent with entity formation.
Coordination with Form SS-4:
This Form 8832 should be filed in coordination with the Form SS-4 (Application for Employer Identification Number) for the Entity. The EIN should be obtained prior to or concurrently with the filing of this Form 8832. If the EIN is obtained prior to filing, the EIN should be entered on Line 2b before submission. If the Form 8832 is filed before the EIN is assigned, the form should note "Applied for" on Line 2b, and a supplemental notification should be sent to the IRS upon receipt of the assigned EIN.
Coordination with Companion Elections:
This Form 8832 is being filed simultaneously with companion Form 8832 elections for Solara Consolidated Master Fund LP and Solara International Feeder (Cayman) LP. All three elections should be filed on or about the same date, with the same effective date of September 15, 2025. The filing of all three elections should be confirmed and documented in the engagement team's tracking system.
Engagement Team:
Document Retention:
•  A copy of this Form 8832 election (as filed) is to be retained in the PLR submission file and cross-referenced in the Closing Checklist — PLR Submission.
•  A copy of this election will be attached to the Entity's first U.S. federal income tax return (Form 1065) for the taxable year that includes September 15, 2025, as required by Treasury Regulation § 301.7701-3(c)(1)(i).
•  The original signed Form 8832 will be sent to the IRS via certified mail, return receipt requested, or via a designated private delivery service approved under Section 7502(f) of the Internal Revenue Code. Proof of mailing and the return receipt (or equivalent delivery confirmation) are to be retained in the engagement file.
•  An electronic copy (PDF) of the signed form and all attachments is to be maintained in the Calderwood & Harkness document management system under Engagement No. 20250527-SDILP-PLR.
End of Form 8832 and Supplemental Statement — Solara Tax-Exempt Feeder (Cayman) LP Prepared by Calderwood & Harkness LLP — Draft dated [________], 2025
Role | Name | Firm
Responsible Partner, Tax | Leonard Cross | Calderwood & Harkness LLP
Lead Associate, Tax | Robert Jansen | Calderwood & Harkness LLP
Authorized Representative (Form 2848) | Leonard Cross | Calderwood & Harkness LLP
Authorized Representative (Form 2848) | Sylvia Hartwell | Calderwood & Harkness LLP

FORM 8832

CONSENT STATEMENT AND SIGNATURE BLOCK

FILING INSTRUCTIONS AND INTERNAL NOTES

Record

Parties

Dates

Amounts