1041-00005 · Client 1041 · IRS Procedural

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CALDERWOOD & HARKNESS LLP

Attorneys at Law

1900 K Street NW, Suite 1100 Washington, DC 20006 Telephone: (202) 555-7400 Facsimile: (202) 555-7401

600 Lexington Avenue, 38th Floor New York, NY 10022 Telephone: (212) 555-9200 Facsimile: (212) 555-9201

August 14, 2025

Internal Revenue Service

Attn: CC:INTL (Office of the Associate Chief Counsel (International))

1111 Constitution Avenue NW Washington, DC 20224

Re: User Fee Payment — Private Letter Ruling Request Taxpayer: Solara Digital Infrastructure LP EIN: 82-4917366 Related Entity: Solara Digital Infrastructure GP LLC (EIN: 82-4917365) Reference: Rev. Proc. 2025-1, Appendix A, Schedule of User Fees

Dear Sir or Madam:

Calderwood & Harkness LLP serves as U.S. tax counsel to Solara Digital Infrastructure LP, a Delaware limited partnership ("Solara" or "SDILP"), headquartered at 1200 Market Street, Suite 3400, Wilmington, Delaware 19801. This letter accompanies the user fee payment submitted in connection with the private letter ruling request (the "PLR Request") being filed on behalf of Solara and certain related entities, as further identified below, regarding the U.S. federal income tax treatment of a proposed multi-step cross-border fund-platform reorganization (the "Proposed Reorganization"). The PLR Request is being submitted concurrently with this user fee transmittal letter as part of the complete PLR submission package.

Calderwood & Harkness LLP has been duly authorized to act on behalf of Solara in connection with the PLR Request and all related matters before the Internal Revenue Service pursuant to IRS Forms 2848 (Powers of Attorney and Declarations of Representative) filed on behalf of Leonard Cross and Sylvia Hartwell, each a Partner of Calderwood & Harkness LLP. Executed copies of the Forms 2848 are enclosed with the PLR Request package for the Service's records.

Identification of Taxpayer and Related Entities

The primary taxpayer requesting the ruling is Solara Digital Infrastructure LP (EIN: 82-4917366), a Delaware limited partnership formed on March 17, 2014 under the Delaware Revised Uniform Limited Partnership Act. Solara's general partner is Solara Digital Infrastructure GP LLC (EIN: 82-4917365), a Delaware limited liability company.

The PLR Request involves the following additional entities, each of which is a party to the Proposed Reorganization or will be formed in connection therewith:

(a) Solara Digital Partners Fund IV LP (EIN: 85-2103748), a Delaware limited partnership;

(b) Solara Digital Partners Fund IV-A (Cayman) LP (U.S. EIN: 98-6241503), a Cayman Islands exempted limited partnership;

(c) Solara Digital Partners Fund IV-B (Luxembourg) SCSp (U.S. EIN: 98-6241571), a Luxembourg special limited partnership (société en commandite spéciale);

(d) Solara Digital Partners Fund V LP (EIN: 88-3467219), a Delaware limited partnership;

(e) Solara Digital Partners Fund V-A (Cayman) LP (U.S. EIN: 98-7891234), a Cayman Islands exempted limited partnership;

(f) Solara Digital Partners Fund V-B (Luxembourg) SCSp (U.S. EIN: 98-7891267), a Luxembourg special limited partnership (société en commandite spéciale);

(g) Solara Consolidated Master Fund LP, a Delaware limited partnership (to be formed in connection with the Proposed Reorganization);

(h) Solara Consolidated Master Fund GP LLC, a Delaware limited liability company (to be formed in connection with the Proposed Reorganization);

(i) Solara International Feeder (Cayman) LP, a Cayman Islands exempted limited partnership (to be formed in connection with the Proposed Reorganization); and

(j) Solara Tax-Exempt Feeder (Cayman) LP, a Cayman Islands exempted limited partnership (to be formed in connection with the Proposed Reorganization).

The PLR Request involves multiple entities with combined assets exceeding $50 million. The total fair market value of assets expected to be transferred in connection with the Proposed Reorganization is approximately $7.75 billion, and the total assets under management across all Solara fund vehicles is approximately $14.7 billion as of March 31, 2025. Accordingly, the applicable user fee category for ruling requests involving multiple entities with combined assets in excess of $50 million applies, as described further below.

Description of the Ruling Request

The PLR Request seeks eight specific rulings confirming the intended U.S. federal income tax treatment of the Proposed Reorganization, which involves the domestication and consolidation of several Cayman Islands and Luxembourg fund vehicles into a newly established Delaware-domiciled master fund structure. The Proposed Reorganization contemplates a series of interrelated steps designed to streamline Solara's existing fund platform, including (i) the formation of new domestic and foreign feeder entities, (ii) the contribution of assets held by the existing Fund IV and Fund V vehicles (and their related Cayman and Luxembourg parallel fund structures) into the newly formed Solara Consolidated Master Fund LP, and (iii) the restructuring of the investment management and carried interest arrangements in connection with the new master-feeder architecture.

The rulings requested concern the application of the following provisions of the Internal Revenue Code of 1986, as amended (the "Code"), and the Treasury Regulations promulgated thereunder:

• Section 721(a) (nonrecognition of gain or loss on contributions to a partnership);

• Section 721(b) (investment partnerships);

• Section 367 (foreign-to-domestic transfers and outbound transfer rules);

• Section 731(a) (nonrecognition on distributions from a partnership);

• Section 731(c) (distributions of marketable securities);

• Section 752 (treatment of certain liabilities);

• Section 704(c) (allocations with respect to contributed property);

• Section 1446 (withholding on effectively connected income allocable to foreign partners); and

• Treasury Regulation § 301.7701-3 (entity classification elections).

The complete PLR Request, together with supporting exhibits (Exhibits A through E), procedural documents (including executed IRS Forms 2848 for Leonard Cross and Sylvia Hartwell), and the Penalties of Perjury Declaration executed by Viktor Raines, Managing Partner and Founder of Solara Digital Infrastructure LP, accompanies this user fee transmittal as part of the full PLR submission package.

User Fee Calculation and Applicable Category

The applicable user fee for the PLR Request is $38,000. This amount has been determined by reference to Rev. Proc. 2025-1, Appendix A, Schedule of User Fees. The applicable fee category is a private letter ruling request involving multiple entities with combined assets exceeding $50 million. A single user fee is submitted to cover the consolidated ruling request for all entities listed above, consistent with the procedures set forth in Rev. Proc. 2025-1.

Method of Payment — Wire Transfer

The user fee of $38,000 is being remitted to the Internal Revenue Service via wire transfer. The details of the wire transfer are as follows:

Amount: $38,000.00

Date of Wire Transfer: August 14, 2025

Originating Bank: Greaves Bancorp (Calderwood & Harkness LLP Trust Account — Firm Bank of Record), ABA Routing No. 021000021

Beneficiary: United States Treasury / Internal Revenue Service

Wire Transfer Reference/Confirmation Number: JPMC-WR-2025-08140038 (a copy of the confirmation is enclosed herewith; the original wire transfer confirmation is maintained in Calderwood & Harkness LLP's engagement file under Engagement No. 20250527-SDILP-PLR)

Reference Line on Wire: "PLR User Fee — Solara Digital Infrastructure LP — EIN 82-4917366"

A copy of the wire transfer confirmation is enclosed with this letter for the Service's records.

Pre-Submission Conference

A pre-submission conference was held on July 22, 2025 with attorneys and technical advisors in the Office of the Associate Chief Counsel (International), CC:INTL Branch 1, regarding the legal issues and factual circumstances addressed in the PLR Request. The PLR Request has been prepared in a manner consistent with the guidance and feedback received during the pre-submission conference, including with respect to the scope of the rulings requested, the format and organization of the submission, and the identification of the relevant Code provisions and regulatory authorities.

We note for the Service's reference that certain aspects of the PLR Request also fall within the secondary jurisdiction of the Office of the Associate Chief Counsel (Passthroughs & Special Industries), CC:PSI, particularly with respect to the rulings requested under Sections 721(a), 704(c), 731(a), 731(c), and 752 of the Code. To the extent that coordination between CC:INTL and CC:PSI is required, we are available to facilitate any such coordination and to provide additional information as may be requested.

Enclosures

The following enclosures accompany this transmittal letter:

1. Wire Transfer Confirmation for the $38,000 user fee payment (Greaves Bancorp, Confirmation No. JPMC-WR-2025-08140038, dated August 14, 2025).

2. Private Letter Ruling Request — Execution Version, submitted under separate cover as part of the full PLR submission package, which includes: PLR Exhibits A through E; executed IRS Forms 2848 (Powers of Attorney and Declarations of Representative) for Leonard Cross and Sylvia Hartwell; and the Penalties of Perjury Declaration signed by Viktor Raines, Managing Partner and Founder of Solara Digital Infrastructure LP.

Contact Information

The Service should direct any questions or correspondence regarding the user fee payment or the PLR Request to the following attorneys at Calderwood & Harkness LLP:

Leonard Cross, Partner — Tax Calderwood & Harkness LLP 1900 K Street NW, Suite 1100 Washington, DC 20006 Telephone: (202) 555-7418

Email: lcross@calderwoodharkness.com

Sylvia Hartwell, Partner — Tax Calderwood & Harkness LLP 600 Lexington Avenue, 38th Floor New York, NY 10022 Telephone: (212) 555-9237

Email: shartwell@calderwoodharkness.com

For internal reference, this matter is maintained under Calderwood & Harkness LLP Engagement No. 20250527-SDILP-PLR.

We appreciate the Service's prompt attention to this submission and look forward to working cooperatively with the assigned examining attorneys to facilitate the timely resolution of the PLR Request. Should additional information or documentation be required in connection with the user fee payment or any other procedural matter, please do not hesitate to contact the undersigned.

Very truly yours,