FORM 2848
Power of Attorney and Declaration of Representative
(Rev. January 2021)
Department of the Treasury — Internal Revenue Service
OMB No. 1545-0150
Instructions: Use Form 2848 to authorize an individual to represent the taxpayer before the IRS. The representative must be an individual eligible to practice before the IRS. See separate instructions for Form 2848. This form is being submitted in connection with a Private Letter Ruling request. For additional information, see Rev. Proc. 2025-1 (or successor guidance).
Note: This completed Form 2848 designates Sylvia Hartwell of Calderwood & Harkness LLP as an authorized representative for all Solara entities identified herein in connection with the private letter ruling request for the cross-border fund-platform reorganization of Solara Digital Infrastructure LP and its affiliated fund vehicles. A companion Form 2848 designating Leonard Cross of Calderwood & Harkness LLP is being filed concurrently.
PART I — POWER OF ATTORNEY
Line 1 — Taxpayer Information
(Taxpayer(s) Must Sign and Date This Form on Page 2, Part II)
The following taxpayer entities hereby grant power of attorney and authorize the representative named in Line 2 below to represent them before the Internal Revenue Service with respect to the matters described in Line 3. Each entity's name, address, taxpayer identification number (EIN), daytime telephone number, and plan number (if applicable) are set forth below.
Entry 1:
Entry 2:
Entry 3:
Entry 4:
Entry 5:
Entry 6:
Entry 7:
Entry 8:
Note: Because the standard Form 2848 does not accommodate all eight taxpayer entities on a single form, a continuation sheet (Form 2848 Supplemental Page) is attached hereto as Attachment A listing all eight entities in the format required by Line 1. The information above is incorporated into and made a part of this Form 2848.
Line 2 — Representative(s)
The following individual is hereby designated as the authorized representative of each of the taxpayer entities identified in Line 1 above:
Line 3 — Acts Authorized
The representative designated in Line 2 is authorized to represent the taxpayer(s) before the Internal Revenue Service with respect to the following tax matters:
Description of Matter:
The authorization granted herein encompasses all matters relating to the Private Letter Ruling Request submitted on or about August 15, 2025, concerning the proposed cross-border fund-platform reorganization of Solara Digital Infrastructure LP and its affiliated fund vehicles, including but not limited to the following:
(a) All issues arising under Internal Revenue Code ("IRC") § 721(a) (nonrecognition of gain or loss on contributions to a partnership), including the treatment of the proposed contribution of assets by the existing Solara fund entities to newly formed or reorganized partnership vehicles;
(b) All issues arising under IRC § 721(b) (gain recognized in certain contributions to partnerships that would be treated as investment companies);
(c) All issues arising under IRC § 723 (basis of property contributed to a partnership);
(d) All issues arising under IRC § 731(a) (recognition of gain or loss on distributions from a partnership), including the treatment of distributions made in connection with the reorganization;
(e) All issues arising under IRC § 731(c) (treatment of marketable securities as money in certain partnership distributions);
(f) All issues arising under IRC § 752 (treatment of certain partnership liabilities), including the allocation of liabilities among the reorganized entities;
(g) All issues arising under IRC § 704(c) (contributions of property with built-in gain or loss), including the application of the remedial allocation method, the traditional method, and the traditional method with curative allocations to assets contributed in the reorganization;
(h) All issues arising under IRC § 367(a) (transfers of property from the United States), including the treatment of outbound transfers of assets to the Cayman and Luxembourg fund vehicles;
(i) All issues arising under IRC § 367(b) (other transfers to and from foreign corporations and entities), including the interaction of § 367(b) with the partnership provisions in the context of the proposed reorganization;
(j) All issues arising under IRC § 1446 (withholding tax on foreign partners' share of effectively connected taxable income);
(k) All issues arising under IRC § 897 (disposition of investment in United States real property), to the extent applicable to the assets held by the fund vehicles;
(l) All issues arising under Treasury Regulations § 301.7701-3 (classification of certain business entities), including the entity classification elections made or to be made by certain entities in the reorganization structure; and
(m) Any and all related matters, ancillary issues, or additional questions raised by the Internal Revenue Service in connection with the foregoing Private Letter Ruling Request.
Specific Use Not Recorded on the Centralized Authorization File (CAF):
Checked — This power of attorney is filed in connection with a specific private letter ruling request and is for a matter that is not typically recorded on the Centralized Authorization File (CAF). The Internal Revenue Service is requested to associate this Form 2848 with the Private Letter Ruling Request filed with CC:INTL and CC:PSI, as applicable. Because this authorization relates to a specific, non-recurring matter (the PLR request), it need not be recorded on the CAF system; however, the taxpayers request that the IRS note the authorization in the PLR file and direct all correspondence and communications to the representative designated herein.
Line 4 — Specific Acts Not Authorized
Unless specifically indicated below, the representative designated in Line 2 is NOT authorized to perform the following acts on behalf of the taxpayer(s):
Sign a return;
Execute a closing agreement under IRC § 7121;
Receive (but not endorse or cash) a refund check;
Substitute another representative or add additional representatives.
All boxes are left unchecked. The authorization granted herein is limited to representation in connection with the Private Letter Ruling Request described in Line 3 above. The representative is not authorized to sign returns, execute closing agreements, receive refund checks, or substitute or add additional representatives unless a supplemental authorization is provided by the taxpayer entities.
Line 5 — Additional Acts Authorized
In addition to the acts generally authorized under this power of attorney, the representative designated in Line 2 is specifically authorized to perform the following acts:
(a) Participate in all conferences, both in-person and telephonic, with the Internal Revenue Service in connection with the above-described Private Letter Ruling Request, including the pre-submission conference scheduled for July 22, 2025, and any subsequent conferences, meetings, or communications relating to the PLR request, whether held at the offices of the IRS National Office in Washington, D.C., or conducted by telephone or other electronic means;
(b) Receive and respond to all IRS correspondence, information document requests, additional information requests, and any other written or oral communications from IRS personnel relating to the PLR request;
(c) Make supplemental submissions, file additional documentation, provide amended or restated representations, and submit revised draft private letter rulings or supplemental ruling requests in connection with the PLR request;
(d) Engage in discussions with IRS attorneys and other personnel assigned to the PLR request regarding the factual representations, legal analysis, and proposed rulings contained in the PLR request; and
(e) Take any and all other actions reasonably necessary or incidental to the foregoing in connection with the PLR request, subject to the limitations set forth in Line 4 above.
Line 6 — Retention/Revocation of Prior Power(s) of Attorney
CHECK HERE if the filing of this power of attorney revokes all prior powers of attorney on file with the Internal Revenue Service for the same matters and years or periods covered by this document.
This box is unchecked. The filing of this power of attorney does NOT revoke any prior powers of attorney on file with the Internal Revenue Service for the same taxpayers or matters. This is an initial filing of Form 2848 with respect to the Private Letter Ruling Request described in Line 3, and no prior power of attorney has been filed with the IRS for this specific matter.
Note: This Form 2848 is being filed concurrently with a companion Form 2848 designating Leonard Cross of Calderwood & Harkness LLP (1900 K Street NW, Suite 1100, Washington, DC 20006) as an additional authorized representative for the same taxpayer entities and the same matters described herein. Both Sylvia Hartwell and Leonard Cross are authorized to act independently on behalf of the taxpayer entities, and both are to receive copies of all IRS notices and communications relating to the PLR request. The concurrent filing of the companion Form 2848 for Leonard Cross is not intended to limit, modify, or revoke the authority granted to Sylvia Hartwell under this Form 2848, and vice versa.
Line 7 — Notices and Communications
Checked: Send copies of notices and communications to the representative designated in Line 2.
All notices and communications from the Internal Revenue Service relating to the matters described in Line 3 should be sent to:
Sylvia Hartwell Calderwood & Harkness LLP 600 Lexington Avenue, 38th Floor New York, NY 10022 Telephone: (212) 819-4500
Fax: (212) 819-4501
Original notices and communications should continue to be sent to the taxpayer entities at:
Solara Digital Infrastructure LP 1200 Market Street, Suite 3400 Wilmington, DE 19801
Attn: Office of the General Counsel
PART II — DECLARATION OF TAXPAYER
Under penalties of perjury, I (we) declare that the taxpayer(s) identified in Line 1 have authorized the representative(s) identified in Line 2 to represent the taxpayer(s) before the Internal Revenue Service for the tax matter(s) described in Line 3 and that, to the best of my (our) knowledge and belief, the information contained in this power of attorney is true, correct, and complete.
I (we) further declare that I am (we are) authorized to execute this Form 2848 on behalf of the taxpayer entities identified in Line 1.
Note on Signing Authority: Viktor Raines signs this Form 2848 in his capacity as Managing Partner of Solara Digital Infrastructure GP LLC (EIN 82-4917365), which serves as the general partner of Solara Digital Infrastructure LP (EIN 82-4917366), Solara Digital Partners Fund IV LP (EIN 85-2103748), and Solara Digital Partners Fund V LP (EIN 88-3467219). For the Cayman Islands entities, Viktor Raines signs in his capacity as a director of Solara Offshore GP Ltd. (a Cayman Islands exempted company), which is the general partner of Solara Digital Partners Fund IV-A (Cayman) LP (EIN 98-6241503) and Solara Digital Partners Fund V-A (Cayman) LP (EIN 98-7891234), with authority to act on behalf of Solara Offshore GP Ltd. in this regard. For the Luxembourg entities, Viktor Raines signs in his capacity as a manager (gérant) of Solara Luxembourg Management S.à r.l. (RCS B 248194), which is the general partner (associé gérant commandité) of Solara Digital Partners Fund IV-B (Luxembourg) SCSp (EIN 98-6241571; RCS B 248193) and Solara Digital Partners Fund V-B (Luxembourg) SCSp (EIN 98-7891267; RCS B 271056), with authority to act on behalf of Solara Luxembourg Management S.à r.l. in this regard. An Authority Clarification Attachment is included as Attachment B hereto, confirming Mr. Raines's authority to execute this Form 2848 on behalf of all eight taxpayer entities.
Signature block — Taxpayer
Signature of or for Taxpayer: ________
Print Name: Viktor Raines
Title: Managing Partner, Solara Digital Infrastructure GP LLC, in its capacity as General Partner of Solara Digital Infrastructure LP, and as General Partner or authorized officer of each of the above-listed fund entities
Date: ________
If additional taxpayer signatures are required: See Attachment C (Additional Taxpayer Signature Page) attached hereto, which includes separate signature lines for each entity, each signed by Viktor Raines in his capacity as the authorized officer or partner of that entity's respective general partner, in the event the Internal Revenue Service requires individual entity-level authorization.
PART III — DECLARATION OF REPRESENTATIVE
Under penalties of perjury, I declare that:
(1) I am not currently under suspension or disbarment from practice before the Internal Revenue Service;
(2) I am subject to regulations contained in Treasury Department Circular No. 230 (31 C.F.R., Part 10), as amended, governing practice before the Internal Revenue Service;
(3) I am aware of, and in compliance with, the regulations contained in Treasury Department Circular No. 230, including the provisions relating to due diligence, conflicts of interest, competence, and professional conduct;
(4) I am authorized to represent the taxpayer(s) identified in Part I for the tax matter(s) specified in Line 3 of this Form 2848; and
(5) I am an individual described in the designation category checked below.
Designation. Designation Category: (a) — Attorney — a member in good standing of the bar of the highest court of a State, possession, territory, commonwealth, or the District of Columbia.
Jurisdiction: State of New York
Licensing/Bar Information: Admitted to the Bar of the State of New York; New York State Bar Registration Number to be inserted upon final execution.
Representative Signature block
Signature of Representative: ________
Print Name: Sylvia Hartwell
Date: ________
ATTACHMENT A
Continuation Sheet — Additional Taxpayer Listing
(Supplement to Form 2848, Line 1)
This continuation sheet is attached to and made a part of the Form 2848 (Rev. January 2021) executed by Viktor Raines on behalf of the taxpayer entities listed below. All entries on this continuation sheet are to be read in conjunction with, and are subject to the same terms and conditions as, the primary Form 2848 to which this sheet is attached.
The following taxpayer entities are listed in continuation of Line 1 of the Form 2848:
Entry 1:
Entry 2:
Entry 3:
Entry 4:
Entry 5:
Entry 6:
Entry 7:
Entry 8:
ATTACHMENT B
Authority Clarification Attachment
(Supplement to Form 2848, Part II — Declaration of Taxpayer)
This attachment is provided to clarify the authority of Viktor Raines to execute the accompanying Form 2848 (Rev. January 2021) on behalf of each of the eight taxpayer entities identified in Line 1 of the Form 2848 and in Attachment A hereto.
Statement of Authority
Viktor Raines, in his capacity as Managing Partner of Solara Digital Infrastructure GP LLC (EIN 82-4917365), is duly authorized to execute the accompanying Form 2848 on behalf of each of the following entities:
1. Solara Digital Infrastructure LP (EIN 82-4917366) — a Delaware limited partnership
2. Solara Digital Infrastructure GP LLC (EIN 82-4917365) — a Delaware limited liability company
3. Solara Digital Partners Fund IV LP (EIN 85-2103748) — a Delaware limited partnership
4. Solara Digital Partners Fund IV-A (Cayman) LP (EIN 98-6241503) — a Cayman Islands exempted limited partnership
5. Solara Digital Partners Fund IV-B (Luxembourg) SCSp (EIN 98-6241571) — a Luxembourg special limited partnership (société en commandite spéciale), RCS B 248193
6. Solara Digital Partners Fund V LP (EIN 88-3467219) — a Delaware limited partnership
7. Solara Digital Partners Fund V-A (Cayman) LP (EIN 98-7891234) — a Cayman Islands exempted limited partnership
8. Solara Digital Partners Fund V-B (Luxembourg) SCSp (EIN 98-7891267) — a Luxembourg special limited partnership (société en commandite spéciale), RCS B 271056
Chain of Authority
The authority of Viktor Raines to execute this Form 2848 on behalf of each of the above-listed entities derives from the following organizational relationships and grant of authority:
U.S. Entities (Entries 1, 2, 3, and 6):
Solara Digital Infrastructure GP LLC (EIN 82-4917365) is a Delaware limited liability company that serves as the sole general partner of each of the following entities: (i) Solara Digital Infrastructure LP (EIN 82-4917366), (ii) Solara Digital Partners Fund IV LP (EIN 85-2103748), and (iii) Solara Digital Partners Fund V LP (EIN 88-3467219). Under the terms of the limited partnership agreements of each of these entities, the general partner has full power and authority to execute any and all documents, instruments, and filings on behalf of the partnership, including filings with the Internal Revenue Service. Viktor Raines serves as the Managing Partner of Solara Digital Infrastructure GP LLC, and pursuant to the operating agreement of Solara Digital Infrastructure GP LLC, the Managing Partner has authority to act on behalf of the company in all matters, including the execution of tax-related filings and authorizations.
With respect to Solara Digital Infrastructure GP LLC itself (Entry 2), Viktor Raines, as its Managing Partner, is authorized to execute filings on behalf of the entity in his capacity as its authorized officer.
Cayman Islands Entities (Entries 4 and 7):
Solara Offshore GP Ltd. is a Cayman Islands exempted company that serves as the sole general partner of each of the following entities: (i) Solara Digital Partners Fund IV-A (Cayman) LP (EIN 98-6241503) and (ii) Solara Digital Partners Fund V-A (Cayman) LP (EIN 98-7891234). Under the terms of the exempted limited partnership agreements of each of these entities, the general partner has full power and authority to execute any and all documents, instruments, and filings on behalf of the partnership, including filings with the United States Internal Revenue Service. Viktor Raines serves as a director of Solara Offshore GP Ltd. and, pursuant to a resolution of the board of directors of Solara Offshore GP Ltd. dated June 12, 2025, has been authorized to act on behalf of Solara Offshore GP Ltd. in connection with the execution of IRS Form 2848 and all matters relating to the Private Letter Ruling Request described herein.
Luxembourg Entities (Entries 5 and 8):
Solara Luxembourg Management S.à r.l. is a Luxembourg private limited liability company (société à responsabilité limitée), registered with the Luxembourg Trade and Companies Register (Registre de Commerce et des Sociétés) under number RCS B 248194, that serves as the general partner (associé gérant commandité) of each of the following entities: (i) Solara Digital Partners Fund IV-B (Luxembourg) SCSp (EIN 98-6241571; RCS B 248193) and (ii) Solara Digital Partners Fund V-B (Luxembourg) SCSp (EIN 98-7891267; RCS B 271056). Under the terms of the limited partnership agreements (contrats de société en commandite spéciale) of each of these entities, the general partner has full power and authority to execute any and all documents, instruments, and filings on behalf of the partnership, including filings with the United States Internal Revenue Service. Viktor Raines serves as a manager (gérant) of Solara Luxembourg Management S.à r.l. and, pursuant to a resolution of the board of managers of Solara Luxembourg Management S.à r.l. dated June 12, 2025, has been authorized to act on behalf of Solara Luxembourg Management S.à r.l. in connection with the execution of IRS Form 2848 and all matters relating to the Private Letter Ruling Request described herein.
Certification. Viktor Raines hereby certifies that the foregoing statements regarding his authority to execute the accompanying Form 2848 on behalf of each of the eight taxpayer entities listed herein are true, correct, and complete. Copies of the relevant organizational documents, limited partnership agreements, operating agreements, and board resolutions evidencing such authority are maintained in the files of Calderwood & Harkness LLP and are available for inspection by the Internal Revenue Service upon request.
________________________________________
Viktor Raines Managing Partner Solara Digital Infrastructure GP LLC
Date: ________
ATTACHMENT C
Additional Taxpayer Signature Page
(Supplement to Form 2848, Part II — Declaration of Taxpayer)
This Additional Taxpayer Signature Page is provided in the event the Internal Revenue Service requires separate, entity-level authorization for each of the eight taxpayer entities identified in Line 1 of the Form 2848 and in Attachment A hereto. Each signature below is executed by Viktor Raines in his capacity as the authorized officer or partner of the respective entity's general partner, as more fully described in Attachment B (Authority Clarification Attachment).
1. Solara Digital Infrastructure LP (EIN 82-4917366)
Signature: ________
Print Name: Viktor Raines
Title: Managing Partner, Solara Digital Infrastructure GP LLC, General Partner
Date: ________
2. Solara Digital Infrastructure GP LLC (EIN 82-4917365)
Signature: ________
Print Name: Viktor Raines
Title: Managing Partner
Date: ________
3. Solara Digital Partners Fund IV LP (EIN 85-2103748)
Signature: ________
Print Name: Viktor Raines
Title: Managing Partner, Solara Digital Infrastructure GP LLC, General Partner
Date: ________
4. Solara Digital Partners Fund IV-A (Cayman) LP (EIN 98-6241503)
Signature: ________
Print Name: Viktor Raines
Title: Director, Solara Offshore GP Ltd., General Partner
Date: ________
5. Solara Digital Partners Fund IV-B (Luxembourg) SCSp (EIN 98-6241571; RCS B 248193)
Signature: ________
Print Name: Viktor Raines
Title: Manager (gérant), Solara Luxembourg Management S.à r.l. (RCS B 248194), General Partner (associé gérant commandité)
Date: ________
6. Solara Digital Partners Fund V LP (EIN 88-3467219)
Signature: ________
Print Name: Viktor Raines
Title: Managing Partner, Solara Digital Infrastructure GP LLC, General Partner
Date: ________
7. Solara Digital Partners Fund V-A (Cayman) LP (EIN 98-7891234)
Signature: ________
Print Name: Viktor Raines
Title: Director, Solara Offshore GP Ltd., General Partner
Date: ________
8. Solara Digital Partners Fund V-B (Luxembourg) SCSp (EIN 98-7891267; RCS B 271056)
Signature: ________
Print Name: Viktor Raines
Title: Manager (gérant), Solara Luxembourg Management S.à r.l. (RCS B 248194), General Partner (associé gérant commandité)
Date: ________
ATTACHMENT D
Cross-Reference to Companion Form 2848
and Filing and Submission Instructions
Companion Form 2848 — Leonard Cross
A companion Form 2848 (Rev. January 2021) is being filed concurrently with this Form 2848, designating the following individual as an additional authorized representative for the same taxpayer entities and the same matters described herein:
Name: Leonard Cross Firm: Calderwood & Harkness LLP Address: 1900 K Street NW, Suite 1100, Washington, DC 20006 Telephone: (202) 756-3200 Fax: (202) 756-3201 Designation: Attorney — admitted to the bar of the District of Columbia
Both Sylvia Hartwell and Leonard Cross are authorized to act independently on behalf of the taxpayer entities with respect to the Private Letter Ruling Request described in Line 3 of the Form 2848. Both representatives are to be listed on the Centralized Authorization File (CAF), to the extent applicable, and both are authorized to receive copies of all IRS notices and communications relating to the PLR request. The concurrent designation of two representatives is intended to facilitate efficient communication with the IRS and does not limit the independent authority of either representative.
Filing and Submission Instructions
This Form 2848, together with Attachments A through D, will be included as part of the Private Letter Ruling request package submitted to:
Internal Revenue Service
Attn: CC:INTL (and CC:PSI, as applicable)
1111 Constitution Avenue NW Washington, DC 20224
Target Submission Date: August 15, 2025
Pre-Submission Conference: A pre-submission conference has been scheduled for July 22, 2025, pursuant to Rev. Proc. 2025-1, § 10.07 (or successor guidance). Sylvia Hartwell and Leonard Cross will participate in the pre-submission conference on behalf of the taxpayer entities. This Form 2848 is being prepared in advance of the pre-submission conference and will be finalized and executed prior to the submission of the PLR request package.
Internal Tracking Information
Calderwood & Harkness Engagement Number: 20250527-SDILP-PLR
Client Distribution: A copy of this Form 2848, together with all attachments, will be retained in the Calderwood & Harkness engagement file and provided to the following individuals at Solara Digital Infrastructure LP for their records:
• Priya Narasimhan, General Counsel, Solara Digital Infrastructure LP
• Stefan Dalmqvist, Head of Tax, Solara Digital Infrastructure LP
All questions regarding this Form 2848 or the associated PLR request should be directed to Sylvia Hartwell at (212) 819-4500 or shartwell@calderwoodharkness.com, or to Leonard Cross at (202) 756-3200 or lcross@calderwoodharkness.com.
END OF FORM 2848 AND ATTACHMENTS
| Field | Information |
| Taxpayer Name | Solara Digital Infrastructure LP |
| Address | 1200 Market Street, Suite 3400, Wilmington, DE 19801 |
| Taxpayer Identification Number (EIN) | 82-4917366 |
| Daytime Telephone Number | (302) 468-7100 |
| Plan Number | N/A |
| Field | Information |
| Taxpayer Name | Solara Digital Infrastructure GP LLC |
| Address | 1200 Market Street, Suite 3400, Wilmington, DE 19801 |
| Taxpayer Identification Number (EIN) | 82-4917365 |
| Daytime Telephone Number | (302) 468-7100 |
| Plan Number | N/A |
| Field | Information |
| Taxpayer Name | Solara Digital Partners Fund IV LP |
| Address | 1200 Market Street, Suite 3400, Wilmington, DE 19801 |
| Taxpayer Identification Number (EIN) | 85-2103748 |
| Daytime Telephone Number | (302) 468-7100 |
| Plan Number | N/A |
| Field | Information |
| Taxpayer Name | Solara Digital Partners Fund IV-A (Cayman) LP |
| Registered Address | Harborstone Corporate Services Ltd., P.O. Box 2714, 94 Solaris Avenue, George Town, Grand Cayman KY1-1111, Cayman Islands |
| U.S. Mailing Address | c/o Solara Digital Infrastructure LP, 1200 Market Street, Suite 3400, Wilmington, DE 19801 |
| Taxpayer Identification Number (EIN) | 98-6241503 |
| Daytime Telephone Number | (302) 468-7100 |
| Plan Number | N/A |
| Field | Information |
| Taxpayer Name | Solara Digital Partners Fund IV-B (Luxembourg) SCSp |
| Registered Address | 14, rue Jean-Pierre Brasseur, L-1258 Luxembourg, Grand Duchy of Luxembourg |
| U.S. Mailing Address | c/o Solara Digital Infrastructure LP, 1200 Market Street, Suite 3400, Wilmington, DE 19801 |
| Taxpayer Identification Number (EIN) | 98-6241571 |
| Daytime Telephone Number | (302) 468-7100 |
| Plan Number | N/A |
| Field | Information |
| Taxpayer Name | Solara Digital Partners Fund V LP |
| Address | 1200 Market Street, Suite 3400, Wilmington, DE 19801 |
| Taxpayer Identification Number (EIN) | 88-3467219 |
| Daytime Telephone Number | (302) 468-7100 |
| Plan Number | N/A |
| Field | Information |
| Taxpayer Name | Solara Digital Partners Fund V-A (Cayman) LP |
| Registered Address | Harborstone Corporate Services Ltd., P.O. Box 2714, 94 Solaris Avenue, George Town, Grand Cayman KY1-1111, Cayman Islands |
| U.S. Mailing Address | c/o Solara Digital Infrastructure LP, 1200 Market Street, Suite 3400, Wilmington, DE 19801 |
| Taxpayer Identification Number (EIN) | 98-7891234 |
| Daytime Telephone Number | (302) 468-7100 |
| Plan Number | N/A |
| Field | Information |
| Taxpayer Name | Solara Digital Partners Fund V-B (Luxembourg) SCSp |
| Registered Address | 14, rue Jean-Pierre Brasseur, L-1258 Luxembourg, Grand Duchy of Luxembourg |
| U.S. Mailing Address | c/o Solara Digital Infrastructure LP, 1200 Market Street, Suite 3400, Wilmington, DE 19801 |
| Taxpayer Identification Number (EIN) | 98-7891267 |
| Daytime Telephone Number | (302) 468-7100 | |
| Plan Number | N/A | |
| Field | Information | |
| Name | Sylvia Hartwell | |
| Firm | Calderwood & Harkness LLP | |
| Address | 600 Lexington Avenue, 38th Floor, New York, NY 10022 | |
| Telephone Number | (212) 819-4500 | |
| Fax Number | (212) 819-4501 | |
| CAF Number | NONE (to be assigned upon processing; this is an initial filing for this representative with respect to these taxpayers) | |
| PTIN | P01827643 | |
| Jurisdiction (State) or Enrollment Card Number | New York — Attorney (licensed and admitted to the bar of the State of New York) | |
| Check if new address | (unchecked) | |
| Check if this representative is to receive copies of notices and communications | (checked — Yes) | |
| Type of Tax | Tax Form Number | Year(s) or Period(s) |
| Income (Federal) — Partnership Returns | Form 1065, Form 8865, and all forms, schedules, and attachments related thereto | Tax years beginning on or after January 1, 2025, and all subsequent tax years affected by the proposed reorganization described herein |
| Private Letter Ruling Request — Cross-Border Fund-Platform Reorganization | Private Letter Ruling Request submitted to the Office of the Associate Chief Counsel (International) (CC:INTL) and the Office of the Associate Chief Counsel (Passthroughs & Special Industries) (CC:PSI) | All matters relating to the Private Letter Ruling Request submitted on or about August 15, 2025 |
| Field | Information | |
| Taxpayer Name | Solara Digital Infrastructure LP | |
| Address | 1200 Market Street, Suite 3400, Wilmington, DE 19801 | |
| EIN | 82-4917366 | |
| Daytime Telephone | (302) 468-7100 | |
| Plan Number | N/A | |
| Field | Information | |
| Taxpayer Name | Solara Digital Infrastructure GP LLC | |
| Address | 1200 Market Street, Suite 3400, Wilmington, DE 19801 |
| EIN | 82-4917365 |
| Daytime Telephone | (302) 468-7100 |
| Plan Number | N/A |
| Field | Information |
| Taxpayer Name | Solara Digital Partners Fund IV LP |
| Address | 1200 Market Street, Suite 3400, Wilmington, DE 19801 |
| EIN | 85-2103748 |
| Daytime Telephone | (302) 468-7100 |
| Plan Number | N/A |
| Field | Information |
| Taxpayer Name | Solara Digital Partners Fund IV-A (Cayman) LP |
| Registered Address | Harborstone Corporate Services Ltd., P.O. Box 2714, 94 Solaris Avenue, George Town, Grand Cayman KY1-1111 |
| U.S. Mailing Address | c/o Solara Digital Infrastructure LP, 1200 Market Street, Suite 3400, Wilmington, DE 19801 |
| EIN | 98-6241503 |
| Daytime Telephone | (302) 468-7100 |
| Plan Number | N/A |
| Field | Information |
| Taxpayer Name | Solara Digital Partners Fund IV-B (Luxembourg) SCSp |
| Registered Address | 14, rue Jean-Pierre Brasseur, L-1258 Luxembourg |
| U.S. Mailing Address | c/o Solara Digital Infrastructure LP, 1200 Market Street, Suite 3400, Wilmington, DE 19801 |
| EIN | 98-6241571 |
| Daytime Telephone | (302) 468-7100 |
| Plan Number | N/A |
| Field | Information |
| Taxpayer Name | Solara Digital Partners Fund V LP |