EFTA Document EFTA01451519

SOF III - 1081 Southern Financial LLC Tax Considerations Certain U.S. Federal Income Tax Considerations The following is a summary of certain U.S. federal income tax consequences of acquiring, holding and disposing of Interests in the Onshore Feeder Fund by U.S. Holders (as defined herein) and of Interests in the Offshore Feeder Fund by U.S. Tax-Exempt Investors (as defined herein) and Non-U.S. Holders (as defined herein) who purchase their respective interests in the offering. This summa