Extract to table

The consideration for the transfer must be paid in cash

The transfer election must be made at the Solstice Holdings level (as the tax partnership and regarded owner of the disregarded entity project companies), and the $64,800,000 in transferred credits must be separated from the $89,040,000 in partnership-retained credits before the Section 704(b) allocation to Ridgeline and CBR Solstice Manager takes effect

To the extent that a particular project's ITCs must be split between the two tranches (i

IRS Registration Portal Under the proposed Treasury regulations (REG-101610-23), both the eligible taxpayer and the transferee taxpayer must complete a pre-filing registration process through an IRS electronic portal before making the transfer election on the eligible taxpayer's tax return

• Employer Identification Number: 06-1938274 • Address: 175 Constitution Plaza, Hartford, Connecticut 06103 • Taxable year in which the credit will be claimed: 2023 • Amount of credit to be received: $60,000,000 Each party must attest to the accuracy of the information provided in the registration under penalties of perjury

The registration must be completed and the registration number must be obtained before the transfer election statement is filed with the eligible taxpayer's tax return