Wise Owl Properties Inc

Part X, Line 2

“All subsidiaries that make up the Organization, except Wise Owl Properties, Inc. are not-for-profit organizations as described in Section 501 (c)(3) of the Internal Revenue Code ("IRC"). Wise Owl Properties, Inc. is a not-for-profit organization as described by 501(c)(2) of the IRC. All entities are exempt from federal and state income taxes on related income pursuant to Section 501(a) of the Internal Revenue Code and Chapter 220.13 of the Florida Statutes, respectively. The Organization evaluates its tax positions of any uncertainties based on the technical merits of the positions taken. Each subsidiary recognizes the tax benefit from an uncertain tax position only if it is more likely than not that the tax position will be upheld on examination by taxing authorities. The Organization has analyzed the tax positions taken and has concluded that as of December 31, 2016 and 2015, there were no uncertain tax positions taken, or expected to be taken, that would require recognition of a liability or disclosure in the consolidated financial statements. Management is required to analyze all open tax years, as defined by the Statutes of Limitations, for all major jurisdictions, including federal and certain state taxing authorities. With few exceptions, at December 31, 2016, the Organization is no longer subject to U.S. federal, state or local income tax examinations by taxing authorities for years before 2013. As of and for the years ended December 31, 2016 and 2015, the Organization did not have a liability for any unrecognized taxes. The Organization has no examinations in progress and is not aware of any tax positions for which it is reasonably possible that the total amounts of unrecognized tax liabilities will significantly change in the next twelve months.”