Agreement to Certain Tax Treatment. Each beneficial owner of the Notes shall, by acquiring a beneficial interest therein, be deemed to have agreed to treat the Notes as indebtedness for U.S. federal income tax purposes.
Agreement to Certain Tax Treatment. The Company and each Holder and each beneficial owner of the Notes and each holder and each beneficial owner of any Underlying Junior Subordinated Notes issued upon conversion of the Notes will, by accepting the Notes and any Underlying Junior Subordinated Notes or a beneficial interest therein, be deemed to have agreed that such Holder or beneficial owner of the Notes and such holder or beneficial owner of the Underlying Junior Subordinated Notes intend that the Notes and any Underlying Junior Subordinated Notes constitute debt and will treat the Notes and any Underlying Junior Subordinated Notes as debt for United States federal, state and local tax purposes.
Agreement to Certain Tax Treatment. The Company, the Guarantor and PartnerRe U.S. Corporation agree, and each Holder and beneficial owner of the Notes will, by accepting the Notes or a beneficial interest therein, be deemed to have agreed, to treat the Notes as indebtedness of PartnerRe U.S. Corporation for U.S. federal income tax purposes, unless otherwise required by applicable law.
Agreement to Certain Tax Treatment. The Issuer, the Guarantor and AXIS Specialty U.S. Holdings, Inc. agree, and each Holder and beneficial owner of the Junior Subordinated Notes will, by accepting the Junior Subordinated Notes or a beneficial interest therein, be deemed to have agreed, to treat the Junior Subordinated Notes as indebtedness of AXIS Specialty U.S. Holdings, Inc. for U.S. federal income tax purposes, unless otherwise required by applicable law.
