0001628280-24-031514 Sample Contracts

TAX MATTERS AGREEMENT
Tax Matters Agreement • July 9th, 2024 • Sunrise Realty Trust, Inc. • Real estate investment trusts • Maryland

This TAX MATTERS AGREEMENT (this “Agreement”) is entered into as of July 8, 2024 by and between AFC GAMMA, INC., a Maryland corporation (“AFC Gamma”), and SUNRISE REALTY TRUST, INC., a Maryland corporation (“SUNS”).

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SEPARATION AND DISTRIBUTION AGREEMENT
Separation and Distribution Agreement • July 9th, 2024 • Sunrise Realty Trust, Inc. • Real estate investment trusts • Maryland

THIS SEPARATION AND DISTRIBUTION AGREEMENT (this “Agreement”), is entered into as of July 8, 2024, by and between AFC Gamma, Inc., a Maryland corporation (“AFC Gamma”), and Sunrise Realty Trust, Inc., a Maryland corporation and a wholly-owned subsidiary of AFC Gamma (“SUNS”) (each a “Party” and together, the “Parties”).

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