EFTA Document EFTA01378890

Significant Incremental After-Tax Benefit From Investing in Qualified Opportunity Zones* QOZs can provide significant tax savings and boost after-tax returns, especially for investors domiciled in states that have high capital gains tax rates but conform to the federal QOZ tax benefit program No-Tax State High-Tax State Taxable QOZ Fund Taxable Investment Investment Investment QOZ Fund Investment 2019 Realized Gain 1,000 1,000 1,000 1,000 2019 Tax Owed on Realized Gain (326) Capital Available for Investment 762 1,000 674 1,000 Income Return 386 506 341 506 Appreciation After 10 Years 1,615 2,119 1,428 2,119 Total Return 2,000 2,625 1,769 2,625 Pre-tax Net IRR 10% 10% 10% 10% State and Federal Ordinary Income Tax 2019.2029 (129) (169) (138) (205) 2026 Deferred Tax Owed on Realized Gain (202) (277) 2029 Tax Owed on Appreciation (203) (246) Post-Tax Profit on Original Realized Investment 669 1,254 386 1,144 Implied Tax Benefit 585 758 Implied Incremental IRR 11% 4.5% • For illustrative purposes only. Return to investors may be materially different from the rate of return assumed above. Note: Assumes sale of Q02 shares in 2029 after 10-year hold, long-term federal capital gains tax rate of 23.8%, no state income tax for No-Tax State and 8.8% state income tax (NY State) for High-Tax State. Pre-tax IRR of 10% is assumed for both the standard taxable investment and the QOZ investment. 4 CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e) CONFIDENTIAL SDNY_GM_00222346 DB-SDNY-0076162 EFTA01378890