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157840 X 2 JONATHAN AND MARGOT DAVIS 125 HIGH STREET SUITE 2111 BOSTON MA 02110 2543849 X 3 JONATHAN AND MARGOT DAVIS 125 HIGH STREET SUITE 2111 BOSTON MA 02110 3510855 X 2 9,141 SHARES SNOWFLAKE COMMON STOCK 2543849 2021-02-01 3 12,811 SHARES OF SNOWFLAKE COMMON STOCK 3510855 2021-08-06 ACCOUNTING 31575 0 0 INFORMATION PROVIDED BY RIVA CAPITAL PARTNERS IV LP: FORM 8886 LINE 7E: THE TAXPAYER IS FILING BECAUSE THEY BECAME AWARE OF THEIR POTENTIAL INVOLVEMENT IN A "TRANSACTION OF INTEREST", WHICH REQUIRES DISCLOSURE UNDER SECTION 1.6001-4(D), SHORTLY AFTER NOVEMBER 1, 2016,WHEN NOTICE 2016-66 ("THE NOTICE") WAS PUBLISHED. THE TAXPAYER HAS TAKEN TAX DEDUCTIONS UNDERIRC 162 FOR INSURANCE PREMIUMS PAID TO GAH INSURANCE COMPANY, LLC ("GAH"), WHO WAS ESTABLISHED IN 2015 AS A CAPTIVE INSURANCE COMPANY UNDER THE LAWS OF THE STATE OF VERMONT. GAH MADE AN IRREVOCABLE ELECTION UNDER SECTION 831(B) IN 2015, TO BE A SMALL INSURANCE COMPANY TAXABLE ONLY ON INVESTMENT INCOME, LESS CERTAIN ADMINISTRATIVE EXPENSES. UNDER THIS ELECTION, ALL UNDERWRITING ACTIVITY IS EXCLUDED FROM GAH'S TAXABLE INCOME WHILE THE TAXPAYER, AS AN INSURED, CAN TAKE A TAX DEDUCTION FOR THE PREMIUMS PAID TO GAH.THE TAXPAYER IS REPORTING ON A PROTECTIVE BASIS AS THEY DO NOT BELIEVE THEY MEET THE CRITERIA FOR REPORTING UNDER THE NOTICE ON AN INDIVIDUAL BASIS. HOWEVER, THE TAXPAYER IS INSURED BY GAH, IS RELATED TO OTHER INSURED ENTITIES AND HAS BEEN INFORMED THAT GAH MEETS THE CRITERIA FOR REPORTING UNDER THE NOTICE.THE TAXPAYER WOULD ONLY LOSE THE TAX DEDUCTION IN THE EVENT THAT GAH FAILED TO QUALIFY AS AN INSURANCE COMPANY FOR FEDERAL TAX PURPOSES. IF THIS WERE TRUE, THE DIRECT TAX BENEFIT WOULD BE DETERMINED SEPARATELY FOR EACH INSURED BASED ON THEIR RESPECTIVE TAX POSITION FOR THE RESPECTIVE TAX YEAR. AS SUCH, THE TAXPAYER IS UNABLE TO QUANTIFY THE ESTIMATED TAX BENEFIT UNDER THESE TRANSACTIONS.THE TAXPAYER HAS NOT RECEIVED ANY DIRECT OR INDIRECT FINANCING, NOR HAVE THEY OTHERWISE BEEN CONVEYED OR AGREED TO RECEIVE LOANS, GUARANTEES OR OTHER TRANSFER OF GAH'S CAPITAL. INFORMATION PROVIDED BY RIVA CAPITAL PARTNERS IV LP: FORM 8886 LINE 7E: THE TAXPAYER IS FILING AS IT IS AWARE OF ITS POTENTIAL INVOLVEMENT IN A "TRANSACTION OF INTEREST", WHICH REQUIRES DISCLOSURE UNDER SECTION 1.6001-4(D) AND PER NOTICE 2016-66 ("THE NOTICE"). THE TAXPAYER HAS TAKEN TAX DEDUCTIONS UNDER IRC 162 FOR INSURANCE PREMIUMS PAID TO GAH INSURANCE COMPANY, LLC ("GAH"), WHICH WAS ESTABLISHED IN 2015 AS A CAPTIVE INSURANCE COMPANY UNDER THE LAWS OF THE STATE OF VERMONT. GAH MADE AN IRREVOCABLE ELECTION UNDER SECTION 831(B) IN 2015, TO BE A SMALL INSURANCE COMPANY TAXABLE ONLY ON INVESTMENT INCOME, LESS CERTAIN ADMINISTRATIVE EXPENSES. UNDER THIS ELECTION, ALL UNDERWRITING ACTIVITY IS EXCLUDED FROM GAH'S TAXABLE INCOME WHILE THE TAXPAYER, AS AN INSURED, CAN TAKE A TAX DEDUCTION FOR THE PREMIUMS PAID TO GAH.THE TAXPAYER IS REPORTING ON A PROTECTIVE BASIS AS THEY DO NOT BELIEVE THEY MEET THE CRITERIA FOR REPORTING UNDER THE NOTICE ON AN INDIVIDUAL BASIS. HOWEVER, THE TAXPAYER IS INSURED BY GAH, IS RELATED TO OTHER INSURED ENTITIES AND HAS BEEN INFORMED THAT GAH MEETS THE CRITERIA FOR REPORTING UNDER THE NOTICE.THE TAXPAYER WOULD ONLY LOSE THE TAX DEDUCTION IN THE EVENT THAT GAH FAILED TO QUALIFY AS AN INSURANCE COMPANY FOR FEDERAL TAX PURPOSES. IF THIS WERE TRUE, THE DIRECT TAX BENEFIT WOULD BE DETERMINED SEPARATELY FOR EACH INSURED BASED ON THEIR RESPECTIVE TAX POSITION FOR THE RESPECTIVE TAX YEAR. AS SUCH, THE TAXPAYER IS UNABLE TO QUANTIFY THE ESTIMATED TAX BENEFIT UNDER THESE TRANSACTIONS.THE TAXPAYER HAS NOT RECIEVED ANY DIRECT OR INDIRECT FINANCING, NOR HAVE THEY OTHERWISE BEEN CONVEYED OR AGREED TO RECEIVE LOANS, GUARANTEES OR OTHER TRANSFER OF GAH'S CAPITAL. INFORMATION PROVIDED BY RIVA CAPITAL PARTNERS V, LP: FORM 8886 LINE 7E: BEGINNING IN THE 2013 TAX YEAR, BAYVILLE HOUSING ASSOCIATES ("TAXPAYER") ENTERED INTO AN INSURANCE ARRANGEMENT FOR FEDERAL INCOME TAX PURPOSES WITH A RELATED ENTITY, RICHMAN SELF INSURANCE, INC. ("CAPTIVE"). TAXPAYER OWNS AN APARTMENT COMMUNITY. TAXPAYER ALONG WITH A LARGE NUMBER OF AFFILIATED ENTITIES ("INSURED AFFILIATES") PROVIDE HOUSING IN THE UNITED STATES. TAXPAYER AND THE INSURED AFFILIATES FOUND THAT THEY WERE UNABLE TO OBTAIN REASONABLY PRICED GENERAL PROPERTY AND CASUALTY INSURANCE COVERAGE FROM THIRD-PARTY INSURANCE COMPANIES FOR NON-CATASTROPHIC EVENTS FOR THE INITIAL-TIER OF COVERAGE FOR LOSSES BELOW $100,000. IN ADDITION, THESE THIRD PARTY INSURANCE COMPANIES IMPOSED COLLECTIVE DAMAGE RECOVERY CAPS ON THESE POLICIES WITH COVERAGE FOR AMOUNTS BELOW $100,000 WHILE CHARGING HIGH PREMIUMS TO THE INSURED. IT WAS WITHIN THIS CONTEXT THAT INDEPENDENT INSURANCE BROKERS RECOMMENDED THAT THE INSURED AFFILIATES ENTER INTO A MASTER INSURANCE POLICY WITH THIRDPARTY INSURANCE COMPANIES WITH A $100,000 PER CLAIM DEDUCTIBLE AND ESTABLISH A CAPTIVE SELFINSURANCE ARRANGEMENT TO REDUCE INSURED AFFILIATES' (INCLUDING TAXPAYER'S) DEDUCTIBLE LOSS EXPOSURES BELOW SUCH A LIMIT. CONSEQUENTLY, RICHARD P. RICHMAN, DAVID A. SALMAN, KRISTIN MILLER, SCOTT RICHMAN, BROOKE RICHMAN, BRIAN MYERS AND THE ELLEN SCHAPPS RICHMAN 2009 GST FAMILY TRUST FORMED CAPTIVE IN 2013 TO PROVIDE COVERAGE TO TAXPAYER AND THE INSURED AFFILIATES FOR NONCATASTROPHIC EVENTS WITH RECOVERIES LESS THAN $100,000. CASUALTY AMOUNTS HIGHER THAN $100,000 WERE AND CONTINUE TO BE PROVIDED BY THIRDPARTY INSURERS. UPON ITS FORMATION, CAPTIVE MADE AN ELECTION PURSUANT TO SECTION 831(B).CAPTIVE WAS FORMED PRINCIPALLY FOR RISK MANAGEMENT PURPOSES AND WAS NOT FORMED FOR EITHER TAX AVOIDANCE OR ESTATE TAX PLANNING PURPOSES. SINCE ITS CREATION, CAPTIVE'S INSURANCE POLICIES HAVE PROVIDED STRAIGHT PROPERTY AND CASUALTY COVERAGE, AND HAVE BEEN UNDERWRITTEN BY A THIRD PARTY. FURTHERMORE, ALL PREMIUM PAYMENTS DUE TO CAPTIVE HAVE BEEN DETERMINED USING ARMSLENGTH STANDARDS AND THE PRIMARY PURPOSE OF THE PREMIUM HAS BEEN TO ADMINISTER AND PAY CLAIMS UNDER CAPTIVE'S RESPECTIVE INSURANCE POLICIES WITH THE INSURED AFFILIATES. CAPTIVE HAS NOT LOANED OR DISTRIBUTED ANY AMOUNTS RECEIVED AS PREMIUMS TO TAXPAYER OR TO ANY OF THE INSURED AFFILIATES. AS OF 12/31/2021 THE CAPTIVE HAS NOT REVOKED ITS SECTION 831(B) ELECTION.IN 2021 TAXPAYER PAID FOR FEDERAL INCOME TAX PURPOSES A TOTAL OF APPROXIMATELY $11,353 TO CAPTIVE IN PREMIUMS. TAXPAYER TOOK A CORRESPONDING DEDUCTION UNDER SECTION 162(A) OF $11,353 ON ITS 2021 U.S. FEDERAL INCOME TAX RETURN. AS DISCUSSED ABOVE, TAXPAYER ENTER INTO THE INSURANCE ARRANGEMENT WITH CAPTIVES SOLELY FOR BUSINESS PURPOSES AS THIS ARRANGEMENT PROVIDED A COST-EFFECTIVE SOLUTION FOR SAVINGS ON OVERALL PROPERTY AND CASUALTY INSURANCE PREMIUMS. TAXPAYER PAID THE PREMIUMS DIRECTLY TO CAPTIVE AND DID NOT RECEIVE ANY FUNDS BACK FROM CAPTIVE. INFORMATION PROVIDED BY RIVA CAPITAL PARTNERS V, LP: FORM 8886 LINE 8A: RICHMAN SELF INSURANCE INC. ("CAPTIVE") IS AN INSURANCE COMPANY SET UP BY AN AFFILIATE OF CAPTIVE AND THE TAXPAYER. TAXPAYER PAID PREMIUMS TO CAPTIVE BEGINNING IN 2013 IN EXCHANGE FOR CAPTIVE PROVIDING INSURANCE COVERAGE FOR NON-CATASTROPHIC PROPERTY AND CASUALTY LOSSES FOR AMOUNTS UNDER THE $100,000 DEDUCTIBLE IMPOSED UNDER THE TAXPAYER'S MASTER INSURANCE PROGRAM WITH THID-PARTY INSURANCE COMPANIES. TAXPAYER ENTERED INTO THIS INSURANCE ARRANGEMENT WITH CAPTIVE AS A COST-EFFECTIVE SOLUTION TO MANAGE ITS OVERALL INSURANCE COSTS AND NOT FOR TAX AVOIDANCE PURPOSES. AS NOTED ABOVE IN LINE 7, SOME OF THE SHAREHOLDERS OF CAPTIVE ALSO INDIRECTLY OWN INTEREST IN TAXPAYER. 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