POTENTIAL OPPORTUNITY ZONE TAX BENEFITS

The primary objective of the Fund’s investment strategy will be the preservation of the Fund’s status as a “qualified opportunity fund” (a “QOF”) in order to permit eligible investors to receive favorable tax treatment under a new tax incentive program created by the 2017 Tax Cuts and Jobs Act.

This program is designed to incentivize investment into designated low-income communities by permitting investors with eligible capital gains to defer, and in some cases, permanently exclude from federal taxation a portion of such gains by investing them in a QOF.

In order to qualify for deferral, an eligible investor must roll over its eligible gains into a QOF within 180 days of the date of the sale or exchange of the property that created the gains.

The investor will then be able to defer recognition of such gains until the earlier of the date of disposition of its interest in the QOF or December 31, 2026.

Investors may also be able to permanently exclude from federal taxation a portion of the eligible gains and, in some cases, also exclude from federal taxation any appreciation in such investor’s investment in the QOF.

“There can be no assurance that, once final Treasury regulations for the federal qualified opportunity zone program are adopted, the Fund will obtain the expected tax benefits from investing in a qualified opportunity zone. See “Tax Disclaimer Statement” below for important information about the tax benefits presented herein.”

TAX DISCLAIMER STATEMENT

The information in this presentation is provided for general information purposes only. You understand and agree that Kirin Capital is not providing any investment, legal, tax, or other professional advice, including with respect to any prospective investment by you in a “qualified opportunity fund” or any prospective investment by the Fund in a federal “qualified opportunity zone” (“QOZ”) within the meaning of the 2017 Tax Cuts and Jobs Act (the “2017 Act”). Without limiting the foregoing, Kirin Capital is not providing any advice with respect to the tax treatment of any such prospective investment, whether under the 2017 Act or otherwise.

The federal QOZ program is newly created and the legislation that created the federal QOZ program is ambiguous in certain material ways that will require additional statutory changes and formal interpretive guidance. Additional proposed and final regulations are expected to be issued, which, when issued may impact the Fund and its investments in unexpected ways, including by making it difficult or impossible to obtain the expected tax benefits sought by the Fund by investing in a QOZ. If the Fund does not satisfy “qualified opportunity fund” requirements, then the tax benefits outlined herein associated with the federal QOZ program may not apply. Further, penalties may be imposed on the Fund unless the Fund has reasonable cause for noncompliance. It is intended that Kirin Capital will operate based on the advice of tax counsel and tax compliance experts; however, formal interpretative guidance from the Internal Revenue Service may still cause the Fund to not satisfy the “qualified opportunity fund” requirements so that the outlined tax benefits may not apply. In addition, to take advantage of such tax benefits, investors must hold their investments in the Fund and the Fund must maintain its status as a “qualified opportunity fund” within the meaning of the 2017 Act for at least 10 years and otherwise satisfy the requirements under the 2017 Act. An attempt to satisfy such requirements may adversely affect the timing or structure of the Fund’s exits from investments or the success of those investments.

Any information provided in this presentation is based on our understanding of current tax law. You are strongly urged to consult your tax advisers prior to investing in the Fund as to, among other things, the advisability of investing in the Fund, the tax consequences of any such investment, and the tax treatment of the Fund’s investment strategy in a QOZ. Kirin Capital disclaims all responsibility for any tax treatment or tax consequences, including with respect to the Fund or a QOZ. Kirin Capital is not responsible for updating any information contained herein based on changes in law or interpretation after the date hereof.

The QOZ program is a federal tax program and states may not conform to the federal QOZ program rules. No information is being provided or considered regarding potential state and local tax consequences resulting from the investment.

The material contained in this brochure is furnished solely for the purpose of considering the purchase/lease of this property and is not to be used for any other purpose. This information should not, under any circumstances, be photocopied or disclosed to any third party without the written consent of Mr. Joseph W. Brady, CCIM, SIOR, President of Joseph W. Brady, Inc., dba The Bradco Companies and collectively Barstow Spanish Trail LLC or used for any purpose whatsoever other than to evaluate the possible purchase/lease of the property.

The only party authorized to represent the Property Owner (“Owner”) in connection with the sale/lease of the property is Joseph W. Brady, Inc., dba The Bradco Companies and collectively Barstow Spanish Trail LLC and no other person is authorized by the Owner to provide any information or to make any representations other than contained in this brochure.

Neither Mr. Joseph W. Brady, CCIM, SIOR, President Joseph W. Brady, Inc., dba The Bradco Companies and collectively Barstow Spanish Trail LLC make any representation or warranty, express or implied, as to the accuracy or completeness of the information contained herein, and nothing contained herein is or shall be relied upon as a promise or a representation as to the future performance of the property. This brochure may include certain statements and estimates by Mr. Joseph W. Brady, CCIM, SIOR, President Joseph W. Brady, Inc., dba The Bradco Companies and collectively Barstow Spanish Trail LLC with respect to the projected future performance of the property. These assumptions may or may not be proven to be correct, and there can be no assurance that such estimates will be achieved. Further, Joseph W. Brady, Inc., dba The Bradco Companies and collectively Barstow Spanish Trail LLC disclaim any and all liability for representations or warranties, expressed or implied, contained in or omitted from this brochure, or any other written or oral communication transmitted or made available to the recipient. The recipient shall be entitled to rely solely on those representations and warranties that may be made to it in any final, fully executed and delivered Real Estate Purchase/Lease Agreement between it and Owner.

The information contained herein is subject to change without notice and the recipient of these materials shall not look to the Joseph W. Brady, Inc., dba The Bradco Companies and collectively Barstow Spanish Trail LLC, nor any of their officers, employees, representatives, independent contractors or affiliates, for the accuracy or completeness thereof. Recipients of this brochure are advised and encouraged to conduct their own comprehensive review and analysis of the property.

This brochure is a solicitation of interest only and is not an offer to sell/lease the property. The Owner expressly reserves the right, at its sole discretion, to reject any or all expressions of interest to purchase/lease the property and expressly reserves the right, at its sole discretion, to terminate negotiations with any entity, for any reason, at any time with or without notice. The Owner shall have no legal commitment or obligation to any entity reviewing the brochure or making an offer to purchase/lease the property unless and until the Owner executes and delivers a signed Real Estate Purchase/Lease Agreement on terms acceptable to Owner, in Owner’s sole discretion. By submitting an offer, a prospective purchaser/lessee will be deemed to have acknowledged the foregoing and agreed to release Joseph W. Brady, Inc., dba The Bradco Companies and collectively Barstow Spanish Trail LLC from any liability with respect thereto.

To the extent Owner or any agent of Owner corresponds with any prospective purchaser/lessee, any prospective purchaser/lessee should not rely on any such correspondence or statements binding Owner. Only a fully executed Real Estate Purchase/Lease Agreement shall bind the property and each prospective purchaser/lessee proceeds at its own risk.