Rural Renewable Energy Alliance

Schedule D, Page 3, Part X

“Rural renewable energy alliance (rreal) is a not-for-profit organization that is exempt from income taxes under section 501(c)(3) of the internal revenue code, except on net income derived from unrelated business activities. Rreal has been classified as an other-than private foundation within the meaning of section 509(a) of the internal revenue code. Rreal is subject to a tax on income from any unrelated business. Income tax benefits are recognized for income tax positions taken or expected to be taken in a tax return, only when it is determined that the income tax position will more-likely-than-not be sustained upon examination by taxing authorities. Rreal and real solar, inc. Have analyzed tax positions taken for filing with the internal revenue service and all state jurisdictions where each entity operates. Rreal and real solar, inc. Believe that income tax filing positions will be sustained upon examination and does not anticipate any adjustments that would result in a material adverse effect on rreal or real solar, inc.'s financial condition, results of operations or cash flows. Accordingly, rreal and real solar, inc. Have not recorded any reserves, or related accruals for interest and penalties for uncertain income tax positions at december 31, 2016 or 2015. The entities are subject to routine audits by taxing jurisdictions; however, there are currently no audits for any tax periods in progress. Rreal believes it is no longer subject to income tax examinations for years prior to 2013. Real solar inc. Is subject to income tax examinations for years beginning in 2014, the year of inception. Rreal paid unrelated business income tax of 0 for 2016 and 2015. Real solar, inc. Paid federal and state income tax of 0 in 2016 and 2,467 in 2015.”