To clarify, Zekret LLC is currently a Delaware limited liability company. However, in consideration of the needs of our investor base — particularly non-U.S. participants — we will be electing to have the entity taxed as a C corporation for U.S. federal tax purposes by filing IRS Form 8832.

This means Zekret LLC will act as a tax blocker, and any income earned by the entity will be taxed at the corporate level. As a result: • The LLC will not be treated as a flow-through entity. • It will not trigger Effectively Connected Income (ECI) for non-U.S. investors. • Non-U.S. investors will not be subject to direct U.S. tax filing obligations arising from their investment in the entity. • Distributions (e.g., dividends), if any, may still be subject to U.S. withholding tax (typically 30%, or lower per treaty), but ECI exposure is eliminated.

We will ensure the proper documentation of this election and reflect the treatment clearly in our updated investment and tax materials. Please let me know if there are any additional details we can provide.