BEAT Tax. (a) During the term of this Agreement, the Reinsurer will not seek to withdraw its 953(d) Election unless (i) the Reinsurer delivers to the Ceding Company a tax opinion of nationally recognized tax counsel, which opinion is reasonably acceptable to the Ceding Company, to the effect that either, (A) the Reinsurer should remain a U.S. Person within the meaning of Section 7701(a)(30) of the Code following such withdrawal, or (B) assuming the Reinsurer were no longer treated as a U.S. Person within the meaning of Section 7701(a)(30) of the Code following such withdrawal, the Reinsurer should not be treated as a “related person” within the meaning of Section 59A(g) of the Code with respect to the Ceding Company or (ii) the Ceding Company consents to such withdrawal, such consent not to be unreasonably withheld, conditioned, or delayed.
Appears in 7 contracts
Samples: Modified Coinsurance Agreement (SAFG Retirement Services, Inc.), Combination Coinsurance and Modified Coinsurance Agreement (SAFG Retirement Services, Inc.), Combination Coinsurance and Modified Coinsurance Agreement (SAFG Retirement Services, Inc.)
