Common use of DAC TAX AGREEMENT Clause in Contracts

DAC TAX AGREEMENT. THE COMPANY and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the following: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulations, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY will submit to THE REINSURER by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER may contest such calculation by providing an alternative calculation to THE COMPANY in writing within 30 days of THE REINSURER's receipt of THE COMPANY's calculation. If THE REINSURER does not so notify THE COMPANY, THE REINSURER will report the net consideration as determined by THE COMPANY in THE REINSURER's tax return for the previous calendar year; e. If THE REINSURER contests THE COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER submits its alternative calculation. If THE COMPANY and THE REINSURER do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective for the 2008 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the following: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulations, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY will submit to THE REINSURER by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER may contest such calculation by providing an alternative calculation to THE COMPANY in writing within 30 days of THE REINSURER's receipt of THE COMPANY's calculation. If THE REINSURER does not so notify THE COMPANY, THE REINSURER will report the net consideration as determined by THE COMPANY in THE REINSURER's tax return for the previous calendar year; e. If THE REINSURER contests THE COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER submits its alternative calculation. If THE COMPANY and THE REINSURER do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective for the 2008 2011 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section Section 15 by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the following: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulations, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY will submit to THE REINSURER by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER may contest such calculation by providing an alternative calculation to THE COMPANY in writing within 30 days of THE REINSURER's receipt of THE COMPANY's calculation. If THE REINSURER does not so notify THE COMPANY, THE REINSURER will report the net consideration as determined by THE COMPANY in THE REINSURER's tax return for the previous calendar year; e. If THE REINSURER contests THE COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER submits its alternative calculation. If THE COMPANY and THE REINSURER do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective for the 2008 2005 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section Section 14 by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the following: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulations, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY will submit to THE REINSURER by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER may contest such calculation by providing an alternative calculation to THE COMPANY in writing within 30 days of THE REINSURER's receipt of THE COMPANY's calculation. If THE REINSURER does not so notify THE COMPANY, THE REINSURER will report the net consideration as determined by THE COMPANY in THE REINSURER's tax return for the previous calendar year; e. If THE REINSURER contests THE COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER submits its alternative calculation. If THE COMPANY and THE REINSURER do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective for the 2008 2005 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY The Ceding Company and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", Reinsurer hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the followingwhereby: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulationsregulations promulgated under Treasury Code Section 848, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY The Ceding Company and THE REINSURER the Reinsurer agree to exchange information pertaining to the net consideration under this Agreement each year to insure ensure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY The Ceding Company will submit to THE REINSURER the Reinsurer by May 1 of each year its calculation of the net consideration for the preceding calendar year.. This schedule of calculations will be accompanied by a statement signed by an officer of the Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year; d. THE REINSURER The Reinsurer may contest such calculation by providing an alternative calculation to THE COMPANY the Ceding Company in writing within 30 days of THE REINSURER's the Reinsurer’s receipt of THE COMPANY's the Ceding Company’s calculation. If THE REINSURER the Reinsurer does not so notify THE COMPANYthe Ceding Company, THE REINSURER the Reinsurer will report the net consideration as determined by THE COMPANY the Ceding Company in THE REINSURER's the Reinsurer’s tax return for the previous calendar year; e. If THE REINSURER the Reinsurer contests THE COMPANY's the Ceding Company’s calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER the Reinsurer submits its alternative calculation. If THE COMPANY the Ceding Company and THE REINSURER do not the Reinsurer reach agreement on the net amount of consideration within consideration, each party will report such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective in their respective tax returns for the 2008 previous calendar tax year year. Both Ceding Company and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY Reinsurer represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC Internal Revenue Code of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the following: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulations, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY will submit to THE REINSURER by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER may contest such calculation by providing an alternative calculation to THE COMPANY in writing within 30 days of THE REINSURER's receipt of THE COMPANY's calculation, or May 1st, if later. If THE REINSURER does not so notify THE COMPANY, THE REINSURER will report the net consideration as determined by THE COMPANY in THE REINSURER's tax return for the previous calendar year; e. If THE REINSURER contests THE COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER submits its alternative calculation. If THE COMPANY and THE REINSURER do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective for the 2008 2005 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY The Ceding Company and THE REINSURER, the Reinsurer herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the followingwhereby: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulationsregulations promulgated under Treasury Code Section 848, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY The Ceding Company and THE REINSURER the Reinsurer agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY The Ceding Company will submit to THE REINSURER the Reinsurer by May 1 of each year its calculation of the net consideration for the preceding calendar year.. This schedule of calculations will be accompanied by a statement signed by an officer of the Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year; d. THE REINSURER The Reinsurer may contest such calculation by providing an alternative calculation to THE COMPANY the Ceding Company in writing within 30 days of THE REINSURERthe Reinsurer's receipt of THE COMPANYthe Ceding Company's calculation. If THE REINSURER the Reinsurer does not so notify THE COMPANYthe Ceding Company, THE REINSURER the Reinsurer will report the net consideration as determined by THE COMPANY the Ceding Company in THE REINSURERthe Reinsurer's tax return for the previous calendar year; e. If THE REINSURER the Reinsurer contests THE COMPANYthe Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER the Reinsurer submits its alternative calculation. If THE COMPANY the Ceding Company and THE REINSURER do not the Reinsurer reach agreement on the net amount of consideration within consideration, each party will report such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective in their respective tax returns for the 2008 previous calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effectyear. THE REINSURER and THE COMPANY Both Parties represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC Internal Revenue Code of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section Section 11 by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the following: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulations, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY will submit to THE REINSURER by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER may contest such calculation by providing an alternative calculation to THE COMPANY in writing within 30 days of THE REINSURER's receipt of THE COMPANY's calculation. If THE REINSURER does not so notify THE COMPANY, THE REINSURER will report the net consideration as determined by THE COMPANY in THE REINSURER's tax return for the previous calendar year; e. If THE REINSURER contests THE COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER submits its alternative calculation. If THE COMPANY and THE REINSURER do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective for the 2008 2004 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY The Ceding Company and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", Reinsurer hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the followingwhereby: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulationsregulations promulgated under Treasury Code Section 848, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY The Ceding Company and THE REINSURER the Reinsurer agree to exchange information pertaining to the net consideration under this Agreement each year to insure ensure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY The Ceding Company will submit to THE REINSURER the Reinsurer by May 1 of each year its calculation of the net consideration for the preceding calendar year.. This schedule of calculations will be accompanied by a statement signed by an officer of the Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year; d. THE REINSURER The Reinsurer may contest such calculation by providing an alternative calculation to THE COMPANY the Ceding Company in writing within 30 days of THE REINSURERthe Reinsurer's receipt of THE COMPANYthe Ceding Company's calculation. If THE REINSURER the Reinsurer does not so notify THE COMPANYthe Ceding Company, THE REINSURER the Reinsurer will report the net consideration as determined by THE COMPANY the Ceding Company in THE REINSURERthe Reinsurer's tax return for the previous calendar year; e. If THE REINSURER the Reinsurer contests THE COMPANYthe Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER the Reinsurer submits its alternative calculation. If THE COMPANY the Ceding Company and THE REINSURER do not the Reinsurer reach agreement on the net amount of consideration within consideration, each party will report such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective in their respective tax returns for the 2008 previous calendar tax year year. Both Ceding Company and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY Reinsurer represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC Internal Revenue Code of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section Section 14 by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the following: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulations, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY will submit to THE REINSURER by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER may contest such calculation by providing an alternative calculation to THE COMPANY in writing within 30 days of THE REINSURER's receipt of THE COMPANY's calculation. If THE REINSURER does not so notify THE COMPANY, THE REINSURER will report the net consideration as determined by THE COMPANY in THE REINSURER's tax return for the previous calendar year; e. If THE REINSURER contests THE COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER submits its alternative calculation. If THE COMPANY and THE REINSURER do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective for the 2008 2004 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section Section 16 by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the following: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulations, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY will submit to THE REINSURER by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER may contest such calculation by providing an alternative calculation to THE COMPANY in writing within 30 days of THE REINSURER's receipt of THE COMPANY's calculation. If THE REINSURER does not so notify THE COMPANY, THE REINSURER will report the net consideration as determined by THE COMPANY in THE REINSURER's tax return for the previous calendar year; e. If THE REINSURER contests THE COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER submits its alternative calculation. If THE COMPANY and THE REINSURER do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective for the 2008 2005 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY The Ceding Company and THE REINSURER, the Reinsurer herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the followingwhereby: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulationsregulations promulgated under Treasury Code Section 848, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1848(c)(1); b. THE COMPANY and THE REINSURER The Ceding Company arid the Reinsurer agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY The Ceding Company will submit to THE REINSURER the Reinsurer by May 1 of each year its calculation of the net consideration for the preceding calendar year.. This schedule of calculations will be accompanied by a statement signed by an officer of the Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year; d. THE REINSURER The Reinsurer may contest such calculation by providing an alternative calculation to THE COMPANY the Ceding Company in writing within 30 days of THE REINSURERthe Reinsurer's receipt of THE COMPANYthe Ceding Company's calculation. If THE REINSURER the Reinsurer does not so notify THE COMPANYthe Ceding Company, THE REINSURER the Reinsurer will report the net consideration as determined by THE COMPANY the Ceding Company in THE REINSURERthe Reinsurer's tax return for the previous calendar year; e. If THE REINSURER the Reinsurer contests THE COMPANYthe Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER the Reinsurer submits its alternative calculation. If THE COMPANY the Ceding Company and THE REINSURER do not the Reinsurer reach agreement on the net amount of consideration within consideration, each party will report such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective in their respective tax returns for the 2008 previous calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effectyear. THE REINSURER and THE COMPANY Both Parties represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 I of the IRC Internal Revenue Code of 1986, as amended.. 0020-2186 8 YRT (02092001)

DAC TAX AGREEMENT. THE COMPANY and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section Section 16 by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the following: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulations, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY will submit to THE REINSURER by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER may contest such calculation by providing an alternative calculation to THE COMPANY in writing within 30 days of THE REINSURER's receipt of THE COMPANY's calculation. If THE REINSURER does not so notify THE COMPANY, THE REINSURER will report the net consideration as determined by THE COMPANY in THE REINSURER's tax return for the previous calendar year; e. If THE REINSURER contests THE COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER submits its alternative calculation. If THE COMPANY and THE REINSURER do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective for the 2008 2004 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the following: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulations, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY will submit to THE REINSURER by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER may contest such calculation by providing an alternative calculation to THE COMPANY in writing within 30 days of THE REINSURER's receipt of THE COMPANY's calculation. If THE REINSURER does not so notify THE COMPANY, THE REINSURER will report the net consideration as determined by THE COMPANY in THE REINSURER's tax return for the previous calendar year; e. If THE REINSURER contests THE COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER submits its alternative calculation. If THE COMPANY and THE REINSURER do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective for the 2008 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. Y-MPVUL-2005-GEN-M-PLAZ THE REINSURER and THE COMPANY represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC of 1986, as amended.

DAC TAX AGREEMENT. THE The CEDING COMPANY and THE REINSURER, the REINSURER herein collectively called called, for the purposes of Section 8 the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the followingwhereby: a. a) For each taxable year under this Agreement, the party Party with the net positive consideration, as defined in the Regulationsregulations promulgated under Treasury Code Section 848, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER b) The Parties agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE c) The CEDING COMPANY will submit to THE the REINSURER by May 1 of each year its calculation of the net consideration for the preceding calendar year.. This schedule of calculations will be accompanied by a statement signed by an officer of the CEDING COMPANY stating that the CEDING COMPANY will report such net consideration in its tax return for the preceding calendar year; d. THE d) The REINSURER may contest such calculation by providing an alternative calculation to THE the CEDING COMPANY in writing within 30 days of THE the REINSURER's 'S receipt of THE the CEDING COMPANY's calculation. If THE the REINSURER does not so notify THE the CEDING COMPANY, THE the REINSURER will report the net consideration as determined by THE the CEDING COMPANY in THE the REINSURER's 'S tax return for the previous calendar year; e. e) If THE the REINSURER contests THE the CEDING COMPANY's calculation of the net consideration, the parties Parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE the REINSURER submits its alternative calculation. If THE the CEDING COMPANY and THE the REINSURER do not reach agreement on the net amount of consideration within consideration, each party shall report such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective in their respective tax returns for the 2008 previous calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effectyear. THE REINSURER and THE COMPANY Both Parties represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC Internal Revenue Code of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY The Ceding Company and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", Reinsurer hereby enter into an election under Treasury Regulations Section 1.8481 .848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the followingwhereby: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulationsregulations promulgated under Treasury Code Section 848, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY The Ceding Company and THE REINSURER the Reinsurer agree to exchange information pertaining to the net consideration under this Agreement each year to insure ensure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY The Ceding Company will submit to THE REINSURER the Reinsurer by May 1 of each year its calculation of the net consideration for the preceding calendar year.. This schedule of calculations will be accompanied by a statement signed by an officer of the Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year; d. THE REINSURER The Reinsurer may contest such calculation by providing an alternative calculation to THE COMPANY the Ceding Company in writing within 30 days of THE REINSURER's the Reinsurer’s receipt of THE COMPANY's the Ceding Company’s calculation. If THE REINSURER the Reinsurer does not so notify THE COMPANYthe Ceding Company, THE REINSURER the Reinsurer will report the net consideration as determined by THE COMPANY the Ceding Company in THE REINSURER's the Reinsurer’s tax return for the previous calendar year; e. If THE REINSURER the Reinsurer contests THE COMPANY's the Ceding Company’s calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER the Reinsurer submits its alternative calculation. If THE COMPANY the Ceding Company and THE REINSURER do not the Reinsurer reach agreement on the net amount of consideration within consideration, each party will report such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective in their respective tax returns for the 2008 previous calendar tax year year. Both Ceding Company and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY Reinsurer represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC Internal Revenue Code of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY FORTIS BENEFITS and THE REINSURERSECURITY, herein collectively called the "“Parties"”, or singularly the "“Party"”, hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the followingwhereby: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulationsregulations promulgated under Treasury Code Section 848, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY FORTIS BENEFITS and THE REINSURER SECURITY agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY FORTIS BENEFITS will submit to THE REINSURER SECURITY by May 1 of each year its calculation of the net consideration for the preceding calendar year.. This schedule of calculations will be accompanied by a statement signed by an officer of FORTIS BENEFITS stating that FORTIS BENEFITS will report such net consideration in its tax return for the preceding calendar year; d. THE REINSURER SECURITY may contest such calculation by providing an alternative calculation to THE COMPANY FORTIS BENEFITS in writing within 30 days of THE REINSURER's SECURITY’s receipt of THE COMPANY's FORTIS BENEFITS calculation. If THE REINSURER SECURITY does not so notify THE COMPANYFORTIS BENEFITS, THE REINSURER SECURITY will report the net consideration as determined by THE COMPANY FORTIS BENEFITS in THE REINSURER's SECURITY’s tax return for the previous calendar year; e. If THE REINSURER SECURITY contests THE COMPANY's FORTIS BENEFITS calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER SECURITY submits its alternative calculation. If THE COMPANY FORTIS BENEFITS and THE REINSURER do not SECURITY reach agreement on the net amount of consideration within consideration, each party shall report such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective in their respective tax returns for the 2008 previous calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effectyear. THE REINSURER and THE COMPANY Both Parties represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC Internal Revenue Code of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the following: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulations, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY will submit to THE REINSURER by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER may contest such calculation by providing an alternative calculation to THE COMPANY in writing within 30 days of THE REINSURER's receipt of THE COMPANY's calculation. If THE REINSURER does not so notify THE COMPANY, THE REINSURER will report the net consideration as determined by THE COMPANY in THE REINSURER's tax return for the previous calendar year; e. If THE REINSURER contests THE COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER submits its alternative calculation. If THE COMPANY and THE REINSURER do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective for the 2008 2010 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY The Ceding Company and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", Reinsurer hereby enter into an election under Treasury Regulations Regulation Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the followingwhereby: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulationsregulations promulgated under Treasury Code Section 848, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY The Ceding Company and THE REINSURER the Reinsurer agree to exchange information pertaining to the net consideration under this Agreement each year to insure ensure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY The Ceding Company will submit to THE REINSURER the Reinsurer by May 1 of each year its calculation of the net consideration for the preceding calendar year.. This schedule of calculations will be accompanied by a statement signed by an officer of the Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year; d. THE REINSURER The Reinsurer may contest such calculation by providing an alternative calculation to THE COMPANY the Ceding Company in writing within 30 days of THE REINSURERthe Reinsurer's receipt of THE COMPANYthe Ceding Company's calculation. If THE REINSURER the Reinsurer does not so notify THE COMPANYthe Ceding Company, THE REINSURER the Reinsurer will report the net consideration as determined by THE COMPANY the Ceding Company in THE REINSURERthe Reinsurer's tax return for the previous calendar year; e. If THE REINSURER the Reinsurer contests THE COMPANYthe Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER the Reinsurer submits its alternative calculation. If THE COMPANY the Ceding Company and THE REINSURER do not the Reinsurer reach agreement on the net amount of consideration within consideration, each party will such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective in their respective tax returns for the 2008 previous calendar tax year year. Both Ceding Company and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY Reinsurer represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1I, or Subpart F of Subchapter N of Chapter 1 I of the IRC Internal Revenue Code of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the following: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulations, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY will submit to THE REINSURER by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER may contest such calculation by providing an alternative calculation to THE COMPANY in writing within 30 days of THE REINSURER's receipt of THE COMPANY's calculation. If THE REINSURER does not so notify THE COMPANY, THE REINSURER will report the net consideration as determined by THE COMPANY in THE REINSURER's tax return for the previous calendar year; e. If THE REINSURER contests THE COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER submits its alternative calculation. If THE COMPANY and THE REINSURER do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective for the 2008 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. Y-MPVUL-2005-GEN-P-PLAZ THE REINSURER and THE COMPANY represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the following: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulations, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service;; [Missing Graphic Reference] c. THE COMPANY will submit to THE REINSURER by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER may contest such calculation by providing an alternative calculation to THE COMPANY in writing within 30 days of THE REINSURER's receipt of THE COMPANY's calculation. If THE REINSURER does not so notify THE COMPANY, THE REINSURER will report the net consideration as determined by THE COMPANY in THE REINSURER's tax return for the previous calendar year; e. If THE REINSURER contests THE COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER submits its alternative calculation. If THE COMPANY and THE REINSURER do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective for the 2008 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section Section 15 by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the following: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulations, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY will submit to THE REINSURER by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER may contest such calculation by providing an alternative calculation to THE COMPANY in writing within 30 days of THE REINSURER's receipt of THE COMPANY's calculation. If THE REINSURER does not so notify THE COMPANY, THE REINSURER will report the net consideration as determined by THE COMPANY in THE REINSURER's tax return for the previous calendar year; e. If THE REINSURER contests THE COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER submits its alternative calculation. If THE COMPANY and THE REINSURER do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective for the 2008 2004 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY The Ceding Company and THE REINSURER, the Reinsurer herein collectively called the "“Parties"”, or singularly the "“Party"”, hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the followingwhereby: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulationsregulations promulgated under Treasury Code Section 848, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY The Ceding Company and THE REINSURER the Reinsurer agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY The Ceding Company will submit to THE REINSURER the Reinsurer by May 1 of each year its calculation of the net consideration for the preceding calendar year.. This schedule of calculations will be accompanied by a statement signed by an officer of the Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year; d. THE REINSURER The Reinsurer may contest such calculation by providing an alternative calculation to THE COMPANY the Ceding Company in writing within 30 days of THE REINSURER's the Reinsurer’s receipt of THE COMPANY's the Ceding Company’s calculation. If THE REINSURER the Reinsurer does not so notify THE COMPANYthe Ceding Company, THE REINSURER the Reinsurer will report the net consideration as determined by THE COMPANY the Ceding Company in THE REINSURER's the Reinsurer’s tax return for the previous calendar year; e. If THE REINSURER the Reinsurer contests THE COMPANY's the Ceding Company’s calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER the Reinsurer submits its alternative calculation. If THE COMPANY the Ceding Company and THE REINSURER do not the Reinsurer reach agreement on the net amount of consideration within consideration, each party will report such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective in their respective tax returns for the 2008 previous calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effectyear. THE REINSURER and THE COMPANY Both Parties represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC Internal Revenue Code of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY The Ceding Company and THE REINSURER, the Reinsurer herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g2(g)(8) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the followingwhereby: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulationsregulations promulgated under Treasury Code Section 848, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1848(c)(1); b. THE COMPANY The Ceding Company and THE REINSURER the Reinsurer agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY The Ceding Company will submit to THE REINSURER the Reinsurer by May 1 of each year its calculation of the net consideration for the preceding calendar year.. This schedule of calculations will be accompanied by a statement signed by an officer of the Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year; d. THE REINSURER The Reinsurer may contest such calculation by providing an alternative calculation to THE COMPANY the Ceding Company in writing within 30 days of THE REINSURERthe Reinsurer's receipt of THE COMPANYthe Ceding Company's calculation. If THE REINSURER the Reinsurer does not so notify THE COMPANYthe Ceding Company, THE REINSURER the Reinsurer will report the net consideration as determined by THE COMPANY the Ceding Company in THE REINSURERthe Reinsurer's tax return for the previous calendar year; e. If THE REINSURER the Reinsurer contests THE COMPANYthe Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER the Reinsurer submits its alternative calculation. If THE COMPANY the Ceding Company and THE REINSURER do not the Reinsurer reach agreement on the net amount of consideration within consideration, each party will report such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective in their respective tax returns for the 2008 previous calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effectyear. THE REINSURER and THE COMPANY Both Parties represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC Internal Revenue Code of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY PRUCO and THE REINSURERSWISS RE, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the followingwhereby: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulationsregulations promulgated under Internal Revenue Code Section 848, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY PRUCO and THE REINSURER SWISS RE agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY PRUCO will submit to THE REINSURER SWISS RE by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER SWISS RE may contest such calculation by providing an alternative calculation to THE COMPANY PRUCO in writing within 30 days of THE REINSURERSWISS RE 's receipt of THE COMPANYPRUCO's calculation. If THE REINSURER SWISS RE does not so notify THE COMPANYPRUCO, THE REINSURER SWISS RE will report the net consideration as determined by THE COMPANY PRUCO in THE REINSURERSWISS RE's tax return for the previous calendar year; e. If THE REINSURER SWISS RE contests THE COMPANYPRUCO's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER SWISS RE submits its alternative calculation. If THE COMPANY PRUCO and THE REINSURER SWISS RE do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY PRUCO and THE REINSURER SWISS RE within 20 days after the expiration of such 30-day period. f. THE COMPANY PRUCO and THE REINSURER SWISS RE agree that this election shall first be effective for the 2008 2000 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER SWISS RE and THE COMPANY PRUCO represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC Internal Revenue Code of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY 1. The Reinsured and THE REINSURERthe Reinsurer, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations "Regulations" and the "IRC. ." Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section Article X by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the following: a. For each taxable year under this Agreement, the party Party with the net positive consideration, as defined in the Regulations, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER The Parties agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY The Reinsured will submit to THE REINSURER the Reinsurer by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER The Reinsurer may contest such calculation by providing an alternative calculation to THE COMPANY the Reinsured in writing within 30 days of THE REINSURERthe Reinsurer's receipt of THE COMPANYthe Reinsured's PLAZ Pruco Re HDI 2.0 Treaty calculation. If THE REINSURER the Reinsurer does not so notify THE COMPANYthe Reinsured, THE REINSURER the Reinsurer will report the net consideration as determined by THE COMPANY the Reinsured in THE REINSURERthe Reinsurer's tax return for the previous calendar year; e. If THE REINSURER the Reinsurer contests THE COMPANYthe Reinsured's calculation of the net consideration, the parties Parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER the Reinsurer submits its alternative calculation. If THE COMPANY the Reinsured and THE REINSURER the Reinsurer do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY the Reinsured and THE REINSURER the Reinsurer within 20 days after the expiration of such 30-day period. f. THE COMPANY The Reinsured and THE REINSURER the Reinsurer agree that this election shall first be effective for the 2008 2012 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER The Reinsured represents and THE COMPANY represent and warrant warrants that they are it is subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY and THE REINSURER, herein collectively called the "Parties", or singularly the "Party", hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section Section 15 by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the following: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulations, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY and THE REINSURER agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY will submit to THE REINSURER by May 1 of each year its calculation of the net consideration for the preceding calendar year. d. THE REINSURER may contest such calculation by providing an alternative calculation to THE COMPANY in writing within 30 days of THE REINSURER's receipt of THE COMPANY's calculation. or May 1st, if later. If THE REINSURER does not so notify THE COMPANY, THE REINSURER will report the net consideration as determined by THE COMPANY in THE REINSURER's tax return for the previous calendar year; e. If THE REINSURER contests THE COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER submits its alternative calculation. If THE COMPANY and THE REINSURER do not reach agreement on the net amount of consideration within such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective for the 2008 2005 calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effect. THE REINSURER and THE COMPANY represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY FORTIS BENEFITS and THE REINSURERSECURITY, herein collectively called the "“Parties"”, or singularly the "“Party"”, hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the followingwhereby: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulationsregulations promulgated under Treasury Code Section 848, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY FORTIS BENEFITS and THE REINSURER SECURITY agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY FORTIS BENEFITS will submit to THE REINSURER SECURITY by May 1 of each year its calculation of the net consideration for the preceding calendar year.. This schedule of calculations will be accompanied by a statement signed by an officer of FORTIS BENEFITS stating that FORTIS BENEFITS will report such net consideration in its tax return for the preceding calendar year; d. THE REINSURER SECURITY may contest such calculation by providing an alternative calculation to THE COMPANY FORTIS BENEFITS in writing within 30 days of THE REINSURER's SECURITY’s receipt of THE COMPANY's calculationFORTIS BENEFITS’ calculation . If THE REINSURER SECURITY does not so notify THE COMPANYFORTIS BENEFITS, THE REINSURER SECURITY will report the net consideration as determined by THE COMPANY FORTIS BENEFITS in THE REINSURER's SECURITY’s tax return for the previous calendar year; e. If THE REINSURER SECURITY contests THE COMPANY's FORTIS BENEFITS’ calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER SECURITY submits its alternative calculation. If THE COMPANY FORTIS BENEFITS and THE REINSURER do not SECURITY reach agreement on the net amount of consideration within consideration, each party shall report such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective in their respective tax returns for the 2008 previous calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effectyear. THE REINSURER and THE COMPANY Both Parties represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC Internal Revenue Code of 1986, as amended.

DAC TAX AGREEMENT. THE COMPANY FORTIS BENEFITS and THE REINSURER, SECURITY herein collectively called the "“Parties"”, or singularly the "“Party"”, hereby enter into an election under Treasury Regulations Section 1.848-2(g) (8) as promulgated under the Internal Revenue Code, as found in Title 26 of the United States Code, hereinafter referred to as the Regulations and the IRC. Both parties agree to make the election contemplated by this ‘DAC TAX AGREEMENT’ section by timely attaching to their U.S. tax returns the schedule contemplated by Section 1.848-2(g)(8)(ii) of the Regulations. Furthermore, the parties agree to the followingwhereby: a. For each taxable year under this Agreement, the party with the net positive consideration, as defined in the Regulationsregulations promulgated under Treasury Code Section 848, will capitalize specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848 (c) (1); b. THE COMPANY FORTIS BENEFITS and THE REINSURER SECURITY agree to exchange information pertaining to the net consideration under this Agreement each year to insure consistency or as otherwise required by the U.S. Internal Revenue Service; c. THE COMPANY FORTIS BENEFITS will submit to THE REINSURER SECURITY by May 1 of each year its calculation of the net consideration for the preceding calendar year.. This schedule of calculations will be accompanied by a statement signed by an officer of FORTIS BENEFITS stating that FORTIS BENEFITS will report such net consideration in its tax return for the preceding calendar year; d. THE REINSURER SECURITY may contest such calculation by providing an alternative calculation to THE COMPANY FORTIS BENEFITS in writing within 30 days of THE REINSURER's SECURITY’s receipt of THE COMPANY's FORTIS BENEFITS’s calculation. If THE REINSURER SECURITY does not so notify THE COMPANYFORTIS BENEFITS, THE REINSURER SECURITY will report the net consideration as determined by THE COMPANY FORTIS BENEFITS in THE REINSURER's SECURITY’s tax return for the previous calendar year; e. If THE REINSURER SECURITY contests THE COMPANY's FORTIS BENEFITS calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within 30 days of the date THE REINSURER SECURITY submits its alternative calculation. If THE COMPANY FORTIS BENEFITS and THE REINSURER do not SECURITY reach agreement on the net amount of consideration within consideration, each party will report such 30-day period, then the net amount of consideration for such year shall be determined by an independent accounting firm acceptable to both THE COMPANY and THE REINSURER within 20 days after the expiration of such 30-day period. f. THE COMPANY and THE REINSURER agree that this election shall first be effective in their respective tax returns for the 2008 previous calendar tax year and will be effective for all subsequent taxable years for which this Agreement remains in effectyear. THE REINSURER and THE COMPANY Both Parties represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the IRC Internal Revenue Code of 1986, as amended.