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Master Tenant Partnership: Inverted Lease. Principal (Managing Member) (Sponsor). Master Tenant Partnership 1. Investor (Tax Equity Investor). 1% “flips” to 95%. 99% “flips” to 5%. Developer Partnership (Lessor). ?% 2. ?% 2. Head Lease of Historic Building.

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slide1

Master Tenant Partnership: Inverted Lease

Principal

(Managing Member)

(Sponsor)

Master

Tenant

Partnership1

Investor

(Tax Equity Investor)

1%

“flips” to

95%

99%

“flips” to

5%

Developer

Partnership

(Lessor)

?%2

?%2

Head

Lease

of Historic

Building

Elect to Pass ITC To “lessee” – Master

Tenant

Partnership

MasterTenant

Partnership1

1%

“flips” to

95%

99%

“flips” to

5%

Sublease

of

Historic Building

Retail Business

1 These are the same entity.

2 No guidance was provided as to parameters of these percentage interests.