Union General Ambulance Service Inc.

Schedule D, Page 3, Part X

“Union, chatuge, the ambulance service, the dialysis clinic, the union general affiliated services, and the north carolina affiliated services are tax exempt under section 501(a) as organizations described in section 501 (c)(3) of the internal revenue code of 1986, as amended. Union general health system segregated portfolio is exempted from all local income, profit, or capital gains taxes until may 1, 2040 under the cayman islands tax concessions law. The corporation applies accounting policies that prescribe when to recognize and how to measure the financial statement effects of income tax positions taken or expected to be taken on its income tax returns. These rules require management to evaluate the likelihood that, upon examination by the relevant taxing jurisdictions, those income tax positions would be sustained. Based on that evaluation, the corporation only recognizes the maximum benefit of each income tax position that is more than 50% likely of being sustained. To the extent that all or a portion of the benefits of an income tax position are not recognized, a liability would be recognized for the unrecognized benefits, along with any interest and penalties that would result from disallowance of the position. Should any such penalties and interest be incurred, they would be recognized as operating expenses. Based on the results of management's evaluation, no liability is recognized in the accompanying balance sheet for unrecognized income tax positions. Further, no interest or penalties have been accrued or charged to expense as of april 30, 2024 and 2023 or for the years then ended. The corporation's tax returns are subject to possible examination by the taxing authorities. For federal income tax purposes, the tax returns essentially remain open for possible examination for a period of three years after the respective filing deadlines of those returns.”