Common use of DAC Tax Election Clause in Contracts

DAC Tax Election. The parties to this Agreement agree to make the election set forth below pursuant to Section 1.848-2(g) (8) of the Income Tax Regulations issued under Section 848 of the Code. This election shall be effective for taxable year 2016 and for all subsequent taxable years for which this Agreement remains in effect. (a) The party with the Net Positive Consideration for this Agreement for each taxable year will capitalize Specified Policy Acquisition Expenses with respect to this Agreement without regard to the General Deductions Limitation of Code Section 848(c)(1). (b) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year, or as otherwise required by the Internal Revenue Service, to ensure consistency. (c) The Company will submit a schedule to the Reinsurer by May 1 of each year with its calculation of the net consideration for the preceding calendar year. The Reinsurer may contest such calculation by providing an alternative calculation to the Company in writing within thirty (30) calendar days of the Reinsurer’s receipt of the Company’s calculation. (d) If the Reinsurer contests the Company’s calculation, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s alternative calculation. If the parties reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns for the preceding year. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. The parties to this Agreement agree to make To the election set forth below pursuant to Section 1.848-2(g) (8) of the Income Tax Regulations issued under extent that Section 848 of the Code. This Code and corresponding Regulation 1.848-2 are applicable to the Reinsured Policies, the Ceding Company and Reinsurer hereby make the joint election shall be effective provided for taxable year 2016 in Regulation 1.848-2(g)(8) and for all subsequent taxable years for which this Agreement remains in effect.agree as follows: (a) The party Party with the Net Positive Consideration net positive consideration for this Agreement for each taxable year will shall capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1).; (b) Both parties agree to Parties shall exchange information pertaining to the amount of net consideration under this Agreement each year, year to ensure consistency or as otherwise required by the Internal Revenue Service, to ensure consistency.; (c) The Ceding Company will shall submit a schedule to the Reinsurer by May 1 of each year with presenting its calculation of the net consideration for the preceding calendar taxable year. The Reinsurer may contest such the calculation in writing within thirty (30) days of receipt of the Ceding Company’s schedule by providing an alternative calculation to the Ceding Company in writing within thirty (30) calendar days of writing. If the Reinsurer does not so notify the Ceding Company, the Reinsurer shall report the net consideration as determined by the Ceding Company in the Reinsurer’s receipt of tax return for the Company’s calculation. (d) previous calendar year. If the Reinsurer contests the Ceding Company’s calculationcalculation of the net consideration, the parties will shall act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s Reinsurer submits its alternative calculation. If the parties reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute Any differences shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation between the parties will utilize so that consistent amounts are reported on the calculation provided by the Company for reporting purposes in their respective income tax returns for the preceding taxable year.; (d) This election to capitalize specified policy acquisition expenses without regard to the general deductions limitation is effective for all taxable years during which this Agreement remains in effect; and (e) Each party will attach a schedule Both Parties agree to its make such election by timely attaching to their federal income tax return for its first taxable year ending after Tax Returns the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under schedule contemplated by Treasury Regulation Section 1.848-2(g)(81.848- 2(g)(8)(ii).

DAC Tax Election. All uncapitalized terms used in this Section 5.2 shall have the meanings set forth in the Treasury regulations under section 848 of the Internal Revenue Code of 1986, as amended (“Code”). (a) The parties Parties will elect, pursuant to Treasury regulations section 1.848-2(g)(8), to determine specified policy acquisition expenses with respect to this Agreement agree without regard to make the election set forth below pursuant to Section 1.848-2(ggeneral deductions limitation of section 848(c)(1) (8) of the Income Tax Regulations issued under Section 848 of the Code. This election shall be effective for taxable the calendar year 2016 ending on or after the Effective Date and for all subsequent taxable years for which any reinsurance agreement is deemed to exist due to an election made pursuant to Section 5.2 of this Agreement. Each Party agrees to attach to its Tax Return filed for the first taxable year ending after this election becomes effective a schedule that identifies this Agreement remains in effect. (a) as the subject of this election. The party Party with the Net Positive Consideration for net positive consideration under this Agreement for each taxable year will shall capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section section 848(c)(1)) of the Code. (b) Both parties To ensure consistency, the Parties agree to exchange information pertaining to the amount of net consideration under deemed to be paid pursuant to any reinsurance agreement deemed to exist due to an election made pursuant to Section 5.2 of this Agreement each year, or as otherwise required by the Internal Revenue Service, to ensure consistency. (c) The Agreement. Ceding Company will shall submit a schedule to the Reinsurer by May March 1 of each year with its calculation that follows a year during which this Agreement was in effect for any portion of such year of Ceding Company’s calculations of the net consideration under this Agreement for the preceding calendar year. The This schedule of calculations shall be accompanied by a statement signed by an officer of Ceding Company stating that Ceding Company will report such net consideration in its federal income tax return for the preceding calendar year. Reinsurer may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) calendar days of the Reinsurer’s receipt of the Ceding Company’s calculation. If Reinsurer does not notify Ceding Company within such time that it contests the calculation, Reinsurer shall report the net consideration as determined by Ceding Company in Reinsurer’s Tax Return for the previous calendar year. (dc) If the Reinsurer contests the Ceding Company’s calculationcalculation of the net consideration, the parties Parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s Reinsurer submits its alternative calculation. If the parties Parties reach an agreement on the an amount of net consideration calculationconsideration, each party Party will report the agreed upon amount in its federal income tax return for the preceding previous calendar year. If the parties during such period, Ceding Company and Reinsurer are unable to reach an agreement on agreement, they shall within ten (10) days of the amount expiration of the thirty (30) day period set forth in this Section 5.2(c), cause a Third Party Accountant promptly to review (which review shall commence no later than five (5) days after the selection of the Third Party Accountant) this Agreement and the calculations of Ceding Company and Reinsurer for the purpose of calculating the net consideration, then the dispute shall be resolved pursuant to Article IX of consideration under this Agreement. If Reinsurer does not contest In making such calculation, the Third Party Accountant shall consider only those items or amounts in Ceding Company’s calculation as to which Reinsurer has disagreed. The Third Party Accountant shall deliver to Ceding Company and Reinsurer, as promptly as practicable (but no later than thirty (30) days after the parties will utilize commencement of its review), a report setting forth such calculation, which calculation shall result in a net consideration between the amount thereof shown in Ceding Company’s calculation provided delivered pursuant to Section 5.2(b) and the amount thereof in Reinsurer’s calculation delivered pursuant to Section 5.2(b). Such report shall be final and binding upon Ceding Company and Reinsurer. The fees, costs and expenses of the Third Party Accountant shall be borne (x) by Ceding Company if the difference between the net consideration as calculated by the Third Party Accountant and Ceding Company’s calculation is greater than the difference between the net consideration as calculated by the Third Party Accountant and Reinsurer’s calculation; (y) by Reinsurer if the first such difference is less than the second such difference; and (z) otherwise equally by Ceding Company for reporting purposes in their respective income tax returns for the preceding yearand Reinsurer. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. The parties to this Agreement agree to Parties shall make the election set forth below provided in Section 1.848-2(g)(8) of the Treasury Regulations under Section 848 of the Code. The specifics of this election are as follows: (a) The Ceding Company and the Reinsurer shall make the following election pursuant to Section 1.848-2(g2(g)(8) (8) of the Income Tax Treasury Regulations issued under Section 848 of the Code. This election shall be effective for taxable the first year 2016 in which this Agreement is effective and for all subsequent taxable years for which this Agreement remains in effect. Each Party shall make the election by timely attaching to its Tax Returns the schedule required by Section 1.848-2(g)(8)(ii) of such Treasury Regulation identifying this Agreement as one for which such election has been made. (ab) The party terms used in this Article VII, and not otherwise defined in this Agreement, are defined by reference to Treasury Regulation Section 1.848-2 in effect on the date this Agreement is executed. (c) The Party with the Net Positive Consideration net positive consideration for this Agreement for each taxable year will shall capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1). (bd) Both parties agree to Parties shall exchange information pertaining to the amount of net consideration under this Agreement each year, year to ensure consistency or as otherwise required by the Internal Revenue Service, to ensure consistency. (ce) The Ceding Company will shall submit a schedule to the Reinsurer by May 1 of each year with of its calculation of the net consideration for the preceding calendar year. This schedule of calculations shall be accompanied by a statement signed by an officer of the Ceding Company stating that the Ceding Company shall report such net consideration in its Tax Return for the preceding calendar year. (f) The Reinsurer may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) calendar days of the Reinsurer’s receipt of the Ceding Company’s calculation. If the Reinsurer does not so notify the Ceding Company, the Reinsurer shall report the net consideration as determined by the Ceding Company in the Reinsurer’s Tax Return for the previous calendar year. (dg) If the Reinsurer contests the Ceding Company’s calculationcalculation of the net consideration, the parties will Parties shall act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s Reinsurer submits its alternative calculation. If the parties Ceding Company and the Reinsurer reach an agreement on the an amount of net consideration calculationconsideration, each party will Party shall report the agreed upon such amount in its income tax return their respective Tax Returns for the preceding previous calendar year. If the parties are unable to Ceding Company and the Reinsurer do not reach an agreement on the amount calculation of net considerationconsideration with such thirty (30) calendar day period, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns net consideration for the preceding year. calendar year shall be determined by an independent accounting firm, selected by the Ceding Company and reasonably acceptable to the Reinsurer, within twenty (e20) Each party will attach a schedule to its federal income tax return for its first taxable year ending calendar days after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8)expiration of such thirty (30) calendar day period. All fees and expenses relating to the work performed by the independent accounting firm shall be shared equally between the Ceding Company and the Reinsurer.

DAC Tax Election. All uncapitalized terms used in this Section 11.01 shall have the meanings set forth in the Treasury Regulations under section 848 of the Internal Revenue Code of 1986, as amended (the “Code”). (a) The parties hereby elect, pursuant to Treasury Regulations section 1.848-2(g)(8), to determine specified policy acquisition expenses with respect to this Agreement agree without regard to make the election set forth below pursuant to Section 1.848-2(ggeneral deductions limitation of section 848(c)(1) (8) of the Income Tax Regulations issued under Section 848 of the Code. This election shall be effective for taxable the calendar year 2016 ending on or after the Applicable Effective Time and for all subsequent taxable years for which any reinsurance agreement is deemed to exist due to an election made pursuant to this Section 11.01. Each party agrees to attach to its Tax Return filed for the first taxable year ending after this election becomes effective a schedule that identifies this Agreement remains in effect. (a) as the subject of this election. The party with the Net Positive Consideration for net positive consideration under this Agreement for each taxable year will shall capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section section 848(c)(1)) of the Code. (b) Both To ensure consistency, the parties agree to exchange information pertaining to the amount of net consideration under deemed to be paid pursuant to any reinsurance agreement deemed to exist due to an election made pursuant to this Agreement each year, or as otherwise required by the Internal Revenue Service, to ensure consistency. (c) Section 11.01. The Ceding Company will shall submit a schedule to the Reinsurer by May March 1 of each year with its calculation that follows a year during which this Agreement was in effect for any portion of such year of the Ceding Company’s calculations of the net consideration under this Agreement for the preceding calendar year. This schedule of calculations shall 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 federal income tax return for the preceding calendar year. The Reinsurer may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) calendar days of the Reinsurer’s receipt of the Ceding Company’s calculation. If the Reinsurer does not notify the Ceding Company within such time that it contests the calculation, the Reinsurer shall report the net consideration as determined by the Ceding Company in the Reinsurer’s Tax Return for the previous calendar year. (dc) If the Reinsurer contests the Ceding Company’s calculationcalculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s Reinsurer submits its alternative calculation. If the parties reach an agreement on the an amount of net consideration calculationconsideration, each party will report the agreed agreed-upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns for the preceding year. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending the previous calendar year. If during such period, the Ceding Company and the Reinsurer are unable to reach agreement, they shall within ten (10) days of the expiration of the thirty (30)-day period set forth in this Section 11.01(c), cause a Third Party Accountant promptly to review (which review shall commence no later than five (5) days after the election becomes effective that identifies selection of the Third Party Accountant) this Agreement and the calculations of the Ceding Company and the Reinsurer for the purpose of calculating the net consideration under this Agreement. In making such calculation, the Third Party Accountant shall consider adjustments to only those items or amounts in the Ceding Company’s calculation as to which the Reinsurer has disagreed. The Third Party Accountant shall deliver to the Ceding Company and the Reinsurer, as promptly as practicable (but no later than thirty (30) days after the commencement of its review), a reinsurance agreement for report setting forth such calculation, which joint elections have been made under Treasury Regulation calculation shall result in a net consideration between the amount thereof shown in the Ceding Company’s calculation delivered pursuant to Section 1.848-2(g)(811.01(b) and the amount thereof in the Reinsurer’s calculation delivered pursuant to Section 11.01(b). Such report shall be final and binding upon the Ceding Company and the Reinsurer. The fees of the Third Party Accountant shall be borne equally by the parties.

DAC Tax Election. The parties to this Agreement agree to make the election set forth below pursuant to Section 1.848-2(g) (8) of the Income Tax Regulations issued under Section 848 of the Code. This election shall be effective for taxable year 2016 and for all subsequent taxable years for which this Agreement remains in effect. (a) The party with the Net Positive Consideration for this Agreement for each taxable year will capitalize Specified Policy Acquisition Expenses with respect to this Agreement without regard to the General Deductions Limitation of Code Section 848(c)(1). (b) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year, or as otherwise required by the Internal Revenue Service, to ensure consistency. (c) The Company will submit a schedule to the Reinsurer by May 1 of each year with its calculation of the net consideration for the preceding calendar year. The Reinsurer may contest such calculation by providing an alternative calculation to the Company in writing within thirty (30) calendar days of the Reinsurer’s 's receipt of the Company’s 's calculation. (d) If the Reinsurer contests the Company’s 's calculation, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s 's alternative calculation. If the parties reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s 's calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns for the preceding year. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. The parties to this Agreement Company and the Reinsurer hereby elect and agree to make the election set forth below pursuant to under Treasury Regulations Section 1.848-2(g2(g)(8) as follows: (8) a) The Company and the Reinsurer will each attach a schedule to its federal income tax return for the first taxable year ending after the Effective Date that identifies this Agreement as a reinsurance agreement for which a joint election under Treasury Regulation Section 1.848-2(g)(8) has been made, and will otherwise file its respective federal income tax returns in a manner consistent with the provisions of Treasury Regulation Section 1.848-2 as in effect on the Income Tax Regulations issued date this Agreement is executed; (b) For each taxable year under this Agreement, the Party with the net positive consideration, as defined in the regulations promulgated under Section 848 of the Code. This election shall be effective for taxable year 2016 and for all subsequent taxable years for which this Agreement remains in effect. (a) The party with the Net Positive Consideration for this Agreement for each taxable year , will capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1).) of the Code; (bc) Both parties The Company and the Reinsurer agree to exchange information pertaining to the amount of net consideration under this Agreement each year, year to ensure consistency or as otherwise required by the Internal Revenue Service, to ensure consistency.Code and applicable Treasury Regulations; (cd) The Company first tax year for which this election is effective is 2011; (e) The Reinsurer will submit a schedule to the Reinsurer Company by May 1 of 15 each year with its calculation of the amount of the net consideration for the preceding calendar year. This schedule of calculations will be accompanied by a statement that the Reinsurer will report such amount of net consideration in its tax return for the preceding calendar year; (f) The Reinsurer Company may contest such calculation by providing an alternative calculation to the Company Reinsurer in writing within thirty (30) calendar days of the Company’s receipt of the Reinsurer’s receipt calculation. If the Company does not so notify the Reinsurer, the Company will report the amount of net consideration as determined by the Reinsurer in the Company’s calculation.tax return for the previous calendar year; (dg) If the Reinsurer Company contests the CompanyReinsurer’s calculationcalculation of the amount of net consideration, the parties Parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s submits its alternative calculation. If the parties reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by Both the Company for reporting purposes in their respective income tax returns for and the preceding yearReinsurer are subject to U.S. taxation under Subchapter L of Chapter 1 of the Code. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. All uncapitalized terms used in this Section 11.01 shall have the meanings set forth in the Treasury Regulations under section 848 of the Internal Revenue Code of 1986, as amended (the “Code”). (a) The parties hereby elect, pursuant to Treasury Regulations section 1.848-2(g)(8), to determine specified policy acquisition expenses with respect to this Agreement agree without regard to make the election set forth below pursuant to Section 1.848-2(ggeneral deductions limitation of section 848(c)(1) (8) of the Income Tax Regulations issued under Section 848 of the Code. This election shall be effective for taxable the calendar year 2016 ending on or after the Effective Time and for all subsequent taxable years for which any reinsurance agreement is deemed to exist due to an election made pursuant to this Section 11.01. Each party agrees to attach to its Tax Return filed for the first taxable year ending after this election becomes effective a schedule that identifies this Agreement remains in effect. (a) as the subject of this election. The party with the Net Positive Consideration for net positive consideration under this Agreement for each taxable year will shall capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section section 848(c)(1)) of the Code. (b) Both To ensure consistency, the parties agree to exchange information pertaining to the amount of net consideration under deemed to be paid pursuant to any reinsurance agreement deemed to exist due to an election made pursuant to this Agreement each year, or as otherwise required by the Internal Revenue Service, to ensure consistency. (c) Section 11.01. The Ceding Company will shall submit a schedule to the Reinsurer by May March 1 of each year with its calculation that follows a year during which this Agreement was in effect for any portion of such year of the Ceding Company’s calculations of the net consideration under this Agreement for the preceding calendar year. This schedule of calculations shall 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 federal income tax return for the preceding calendar year. The Reinsurer may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) calendar days of the Reinsurer’s receipt of the Ceding Company’s calculation. If the Reinsurer does not notify the Ceding Company within such time that it contests the calculation, the Reinsurer shall report the net consideration as determined by the Ceding Company in the Reinsurer’s Tax Return for the previous calendar year. (dc) If the Reinsurer contests the Ceding Company’s calculationcalculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s Reinsurer submits its alternative calculation. If the parties reach an agreement on the an amount of net consideration calculationconsideration, each party will report the agreed agreed-upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns for the preceding year. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending the previous calendar year. If during such period, the Ceding Company and the Reinsurer are unable to reach agreement, they shall within ten (10) days of the expiration of the thirty (30)-day period set forth in this Section 11.01(c), cause a Third Party Accountant promptly to review (which review shall commence no later than five (5) days after the election becomes effective that identifies selection of the Third Party Accountant) this Agreement and the calculations of the Ceding Company and the Reinsurer for the purpose of calculating the net consideration under this Agreement. In making such calculation, the Third Party Accountant shall consider adjustments to only those items or amounts in the Ceding Company’s calculation as a reinsurance agreement for to which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).the

DAC Tax Election. The parties to this Agreement Company and the Reinsurer hereby elect and agree to make the election set forth below pursuant to under Treasury Regulations Section 1.848-2(g2(g)(8) as follows: (8) a) The Company and the Reinsurer will each attach a schedule to its federal income tax return for the first taxable year ending after the Effective Date that identifies this Agreement as a reinsurance agreement for which a joint election under Treasury Regulation Section 1.848-2(g)(8) has been made, and will otherwise file its respective federal income tax returns in a manner consistent with the provisions of Treasury Regulation Section 1.848-2 as in effect on the Income Tax Regulations issued date this Agreement is executed; (b) For each taxable year under this Agreement, the Party with the net positive consideration, as defined in the regulations promulgated under Section 848 of the Code. This election shall be effective for taxable year 2016 and for all subsequent taxable years for which this Agreement remains in effect. (a) The party with the Net Positive Consideration for this Agreement for each taxable year , will capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1).) of the Code; (bc) Both parties The Company and the Reinsurer agree to exchange information pertaining to the amount of net consideration under this Agreement each year, year to ensure consistency or as otherwise required by the Internal Revenue Service, to ensure consistency.Code and applicable Treasury Regulations; (cd) The Company first tax year for which this election is effective is 2013; (e) The Reinsurer will submit a schedule to the Reinsurer Company by May 1 of 15 each year with its calculation of the amount of the net consideration for the preceding calendar year. This schedule of calculations will be accompanied by a statement that the Reinsurer will report such amount of net consideration in its tax return for the preceding calendar year; (f) The Reinsurer Company may contest such calculation by providing an alternative calculation to the Company Reinsurer in writing within thirty (30) calendar days of the Company’s receipt of the Reinsurer’s receipt of the Company’s calculation. (d) If the Reinsurer contests the Company’s calculation, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s alternative calculation. If the parties reach an agreement on Company does not so notify the net consideration calculationReinsurer, each party the Company will report the agreed upon amount of net consideration as determined by the Reinsurer in its income the Company’s tax return for the preceding previous calendar year. ; (g) If the parties are unable to reach an agreement on Company contests the Reinsurer’s calculation of the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreementin accordance with Section 10.2. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by Both the Company for reporting purposes in their respective income tax returns for and the preceding yearReinsurer are subject to U.S. taxation under Subchapter L of Chapter 1 of the Code. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. The parties to this Agreement agree to make the election set forth below pursuant to Section 1.848-2(g) (8) of the Income Tax Regulations issued under Section 848 of the Internal Revenue Code of 1986, as amended (the “Code”). This election shall be effective for taxable year 2016 2013 and for all subsequent taxable years for which this Agreement remains in effect. (a) The party with the Net Positive Consideration for this Agreement for each taxable year will capitalize Specified Policy Acquisition Expenses with respect to this Agreement without regard to the General Deductions Limitation of Code Section 848(c)(1). (b) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year, or as otherwise required by the Internal Revenue Service, to ensure consistency. (c) The Company will submit a schedule to the Reinsurer by May 1 of each year with its calculation of the net consideration for the preceding calendar year. This schedule will be accompanied by a statement signed by an officer of the Company attesting to the calculation contained in said schedule. The Reinsurer may contest such calculation by providing an alternative calculation to the Company in writing within thirty (30) calendar days of the Reinsurer’s receipt of the Company’s calculation. (d) If the Reinsurer contests the Company’s calculation, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s alternative calculation. If the parties reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns for the preceding year. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. The parties to this Agreement agree to Parties shall make the election set forth below provided in Section 1.848- 2(g)(8) of the Treasury Regulations under Section 848 of the Code. The specifics of this election are as follows: (a) The Ceding Company and the Reinsurer shall make the following election pursuant to Section 1.848-2(g2(g)(8) (8) of the Income Tax Treasury Regulations issued under Section 848 of the Code. This election shall be effective for taxable the first year 2016 in which this Agreement is effective and for all subsequent taxable years for which this Agreement remains in effect. Each Party shall make the election by timely attaching to its Tax Returns the schedule required by Section 1.848-2(g)(8)(ii) of such Treasury Regulation identifying this Agreement as one for which such election has been made. (ab) The party terms used in this Article VII, and not otherwise defined in this Agreement, are defined by reference to Treasury Regulation Section 1.848-2 in effect on the date this Agreement is executed. (c) The Party with the Net Positive Consideration net positive consideration for this Agreement for each taxable year will shall capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1). (bd) Both parties agree to Parties shall exchange information pertaining to the amount of net consideration under this Agreement each year, year to ensure consistency or as otherwise required by the Internal Revenue Service, to ensure consistency. (ce) The Ceding Company will shall submit a schedule to the Reinsurer by May 1 of each year with of its calculation of the net consideration for the preceding calendar year. This schedule of calculations shall be accompanied by a statement signed by an officer of the Ceding Company stating that the Ceding Company shall report such net consideration in its Tax Return for the preceding calendar year. (f) The Reinsurer may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) calendar days of the Reinsurer’s receipt of the Ceding Company’s calculation. If the Reinsurer does not so notify the Ceding Company, the Reinsurer shall report the net consideration as determined by the Ceding Company in the Reinsurer’s Tax Return for the previous calendar year. (dg) If the Reinsurer contests the Ceding Company’s calculationcalculation of the net consideration, the parties will Parties shall act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s Reinsurer submits its alternative calculation. If the parties Ceding Company and the Reinsurer reach an agreement on the an amount of net consideration calculationconsideration, each party will Party shall report the agreed upon such amount in its income tax return their respective Tax Returns for the preceding previous calendar year. If the parties are unable to Ceding Company and the Reinsurer do not reach an agreement on the amount calculation of net considerationconsideration with such thirty (30) calendar day period, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns net consideration for the preceding year. calendar year shall be determined by an independent accounting firm, selected by the Ceding Company and reasonably acceptable to the Reinsurer, within twenty (e20) Each party will attach a schedule to its federal income tax return for its first taxable year ending calendar days after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8)expiration of such thirty (30) calendar day period. All fees and expenses relating to the work performed by the independent accounting firm shall be shared equally between the Ceding Company and the Reinsurer.

DAC Tax Election. The parties to this Agreement Company and the Reinsurer hereby elect and agree to make the election set forth below pursuant to under Treasury Regulations Section 1.848-2(g2(g)(8) as follows: (8) a) The Company and the Reinsurer will each attach a schedule to its federal income tax return for the first taxable year ending after the Effective Date that identifies this Agreement as a reinsurance agreement for which a joint election under Treasury Regulation Section 1.848-2(g)(8) has been made, and will otherwise file its respective federal income tax returns in a manner consistent with the provisions of Treasury Regulation Section 1.848-2 as in effect on the Income Tax Regulations issued date this Agreement is executed; (b) For each taxable year under this Agreement, the Party with the net positive consideration, as defined in the regulations promulgated under Section 848 of the Code. This election shall be effective for taxable year 2016 and for all subsequent taxable years for which this Agreement remains in effect. (a) The party with the Net Positive Consideration for this Agreement for each taxable year , will capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1).) of the Code; (bc) Both parties The Company and the Reinsurer agree to exchange information pertaining to the amount of net consideration under this Agreement each year, year to ensure consistency or as otherwise required by the Internal Revenue Service, to ensure consistency.Code and applicable Treasury Regulations; (cd) The Company first tax year for which this election is effective is 2013; (e) The Reinsurer will submit a schedule to the Reinsurer Company by May 1 of 15 each year with its calculation of the amount of the net consideration for the preceding calendar year. This schedule of calculations will be accompanied by a statement that the Reinsurer will report such amount of net consideration in its tax return for the preceding calendar year; (f) The Reinsurer Company may contest such calculation by providing an alternative calculation to the Company Reinsurer in writing within thirty (30) calendar days of the ReinsurerCompany’s receipt of the Company’s calculation. (d) If the Reinsurer contests the Company’s calculation, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s alternative calculation. If the parties reach an agreement on Company does not so notify the net consideration calculationReinsurer, each party the Company will report the agreed upon amount of net consideration as determined by the Reinsurer in its income the Company’s tax return for the preceding previous calendar year. ; (g) If the parties are unable to reach an agreement on Company contests the Reinsurer’s calculation of the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreementin accordance with Section 10.2. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by Both the Company for reporting purposes in their respective income tax returns for and the preceding yearReinsurer are subject to U.S. taxation under Subchapter L of Chapter 1 of the Code. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. The parties to this Agreement Company and the Reinsurer hereby elect and agree to make the election set forth below pursuant to under Treasury Regulations Section 1.848-2(g2(g)(8) as follows: (8) a) The Company and the Reinsurer will each attach a schedule to its federal income tax return for the first taxable year ending after the Effective Date that identifies this Agreement as a reinsurance agreement for which a joint election under Treasury Regulation Section 1.848-2(g)(8) has been made, and will otherwise file its respective federal income tax returns in a manner consistent with the provisions of Treasury Regulation Section 1.848-2 as in effect on the Income Tax Regulations issued date this Agreement is executed; (b) For each taxable year under this Agreement, the Party with the net positive consideration, as defined in the regulations promulgated under Section 848 of the Code. This election shall be effective for taxable year 2016 and for all subsequent taxable years for which this Agreement remains in effect. (a) The party with the Net Positive Consideration for this Agreement for each taxable year , will capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1).) of the Code; (bc) Both parties The Company and the Reinsurer agree to exchange information pertaining to the amount of net consideration under this Agreement each year, year to ensure consistency or as otherwise required by the Internal Revenue Service, to ensure consistency.Code and applicable Treasury Regulations; (cd) The Company first tax year for which this election is effective is 2013; (e) The Reinsurer will submit a schedule to the Reinsurer Company by May 1 of 15 each year with its calculation of the amount of the net consideration for the preceding calendar year. This schedule of calculations will be accompanied by a statement that the Reinsurer will report such amount of net consideration in its tax return for the preceding calendar year; (f) The Reinsurer Company may contest such calculation by providing an alternative calculation to the Company Reinsurer in writing within thirty (30) calendar days of the Company’s receipt of the Reinsurer’s receipt of the Company’s calculation. (d) If the Reinsurer contests the Company’s calculation, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s alternative calculation. If the parties reach an agreement on Company does not so notify the net consideration calculationReinsurer, each party the Company will report the agreed upon amount of net consideration as determined by the Reinsurer in its income the Company’s tax return for the preceding previous calendar year. ; (g) If the parties are unable to reach an agreement on Company contests the Reinsurer’s calculation of the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreementin accordance with Section 11.2. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by Both the Company for reporting purposes in their respective income tax returns for and the preceding yearReinsurer are subject to U.S. taxation under Subchapter L of Chapter 1 of the Code. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. The parties to this Agreement agree to Parties shall make the election set forth below provided in Section 1.848-2(g)(8) of the Treasury Regulations under Section 848 of the Code. The specifics of this election are as follows: (a) The Ceding Company and the Reinsurer shall make the following election pursuant to Section 1.848-2(g2(g)(8) (8) of the Income Tax Treasury Regulations issued under Section 848 of the Code. This election shall be effective for taxable the first year 2016 in which this Agreement is effective and for all subsequent taxable years for which this Agreement remains in effect. Each Party shall make the election by timely attaching to its Tax Returns the schedule required by Section 1.848-2(g)(8)(ii) of such Treasury Regulation identifying this Agreement as one for which such election has been made. (ab) The party terms used in this Article VI, and not otherwise defined in this Agreement, are defined by reference to Treasury Regulation Section 1.848-2 in effect on the date this Agreement is executed. (c) The Party with the Net Positive Consideration net positive consideration for this Agreement for each taxable year will shall capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1). (bd) Both parties agree to Parties shall exchange information pertaining to the amount of net consideration under this Agreement each year, year to ensure consistency or as otherwise required by the Internal Revenue Service, to ensure consistency. (ce) The Ceding Company will shall submit a schedule to the Reinsurer by May 1 of each year with of its calculation of the net consideration for the preceding calendar year. This schedule of calculations shall be accompanied by a statement signed by an officer of the Ceding Company stating that the Ceding Company shall report such net consideration in its Tax Return for the preceding calendar year. (f) The Reinsurer may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) calendar days of the Reinsurer’s receipt of the Ceding Company’s calculation. If the Reinsurer does not so notify the Ceding Company, the Reinsurer shall report the net consideration as determined by the Ceding Company in the Reinsurer’s Tax Return for the previous calendar year. (dg) If the Reinsurer contests the Ceding Company’s calculationcalculation of the net consideration, the parties will Parties shall act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s Reinsurer submits its alternative calculation. If the parties Ceding Company and the Reinsurer reach an agreement on the an amount of net consideration calculationconsideration, each party will Party shall report the agreed upon such amount in its income tax return their respective Tax Returns for the preceding previous calendar year. If the parties are unable to Ceding Company and the Reinsurer do not reach an agreement on the amount calculation of net considerationconsideration with such thirty (30) calendar day period, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns net consideration for the preceding year. calendar year shall be determined by an independent accounting firm, selected by the Ceding Company and reasonably acceptable to the Reinsurer, within twenty (e20) Each party will attach a schedule to its federal income tax return for its first taxable year ending calendar days after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8)expiration of such thirty (30) calendar day period. All fees and expenses relating to the work performed by the independent accounting firm shall be shared equally between the Ceding Company and the Reinsurer.

DAC Tax Election. The parties to this Agreement Ceding Company and the Reinsurer hereby elect and agree to make the election set forth below pursuant to under Treasury Regulations Section 1.848-2(g2(g)(8) as follows: (8) a) The Ceding Company and the Reinsurer will each attach a schedule to its federal income tax return for the first taxable year ending after the Effective Date that identifies this Agreement as a reinsurance agreement for which a joint election under Treasury Regulation Section 1.848-2(g)(8) has been made, and will otherwise file its respective federal income tax returns in a manner consistent with the provisions of Treasury Regulation Section 1.848-2 as in effect on the Income Tax Regulations issued date this Agreement is executed; (b) For each taxable year under this Agreement, the party hereto with the net positive consideration, as defined in the regulations promulgated under Section 848 of the Code. This election shall be effective for taxable year 2016 and for all subsequent taxable years for which this Agreement remains in effect. (a) The party with the Net Positive Consideration for this Agreement for each taxable year , will capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1).) of the Code; (bc) Both parties The Ceding Company and the Reinsurer agree to exchange information pertaining to the amount of net consideration under this Agreement each year, year to ensure consistency or as otherwise required by the Internal Revenue Service, to ensure consistency.Code and applicable Treasury Regulations; (cd) The Company first tax year for which this election is effective is 2018; (e) The Reinsurer will submit a schedule to the Reinsurer Ceding Company by May 1 of 15 each year with its calculation of the amount of the net consideration for the preceding calendar year. This schedule of calculations will be accompanied by a statement that the Reinsurer will report such amount of net consideration in its tax return for the preceding calendar year; (f) The Reinsurer Ceding Company may contest such calculation by providing an alternative calculation to the Company Reinsurer in writing within thirty (30) calendar days of the ReinsurerCeding Company’s receipt of the Reinsurer’s calculation. If the Ceding Company does not so notify the Reinsurer, the Ceding Company will report the amount of net consideration as determined by the Reinsurer in the Ceding Company’s calculation.tax return for the previous calendar year; (dg) If the Reinsurer Ceding Company contests the CompanyReinsurer’s calculationcalculation of the amount of net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that on which the Ceding Company receives the Reinsurer’s submits its alternative calculation. If Both the parties reach an agreement on Ceding Company and the net consideration calculation, each party will report Reinsurer are subject to U.S. taxation under Subchapter L of Chapter 1 of the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns for the preceding yearCode. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. The parties Both Parties hereby enter into a joint election under Treasury Regulations Section 1.8482(g)(8) whereby: (a) For each taxable year under this Agreement, the party with net positive consideration, (as defined in Treasury Code Section 848 and Treasury Regulations issued thereunder) for such taxable year will capitalize specified policy acquisition expenses with respect to this Agreement agree without regard to make the general deductions limitation of Internal Revenue Code Section 848(c)(1). (b) This election set forth below pursuant to Section 1.848-2(g) (8) will be effective as of the Income Tax Regulations issued under Section 848 beginning of the Codetaxable year for each party that includes the Effective Time of this Agreement. Each party shall attach a schedule to its federal income tax return for that taxable year which identifies this Agreement as a reinsurance agreement for which the joint election has been made. This election shall be effective for taxable year 2016 and will remain in effect for all subsequent future taxable years for which this Agreement remains in effect, and may not be revoked by the parties except as provided for by Applicable Law. (a) The party with the Net Positive Consideration for this Agreement for each taxable year will capitalize Specified Policy Acquisition Expenses with respect to this Agreement without regard to the General Deductions Limitation of Code Section 848(c)(1). (bc) Both parties agree to exchange information pertaining to the amount of net consideration under for this Agreement each year, or as otherwise required by the Internal Revenue Service, and all reinsurance agreements in force between them (if any) to ensure consistencyconsistency for purposes of complying with the joint election. The amount of net consideration will be a net positive consideration for one party and a net negative consideration for the other party. (cd) The Company Reinsurer will submit a schedule to the Reinsurer Company by May 1 1st of each year with of its calculation of the net consideration for the preceding calendar year. This schedule will be accompanied by a statement signed by an officer of Reinsurer stating that Reinsurer will report such net consideration in its tax return for the preceding calendar year in accordance with the terms of this election. (e) The Reinsurer Company may contest such calculation by providing an alternative calculation to the Company Reinsurer in writing within thirty (30) calendar days of the Reinsurer’s receipt of the Company’s calculation. (d) If the Reinsurer contests the Company’s calculation, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days receipt of the date that the Company receives the Reinsurer’s alternative calculation. If the parties reach an agreement Company does not so notify Reinsurer, the Company will report on its tax return the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided consistent with that determined by the Company for reporting purposes in their respective income tax returns for the preceding yearReinsurer. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. The parties to this Agreement agree to make the election set forth below pursuant to Section 1.848-2(g) (8) of the Income income Tax Regulations issued under Section 848 of the Internal Revenue Code of 1986, as amended (the "Code"). This election shall be effective for taxable year 2016 2012 and for all subsequent taxable years for which this Agreement remains in effect. (a) The party with the Net Positive Consideration for this Agreement for each taxable year will capitalize Specified Policy Acquisition Expenses with respect to this Agreement without regard to the General Deductions Limitation of Code Section 848(c)(1). (b) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year, or as otherwise required by the Internal Revenue Service, to ensure consistency. (c) The Company will submit a schedule to the Reinsurer by May 1 of each year with its calculation of the net consideration for the preceding calendar year. This schedule will be accompanied by a statement signed by an officer of the Company attesting to the calculation contained in said schedule. The Reinsurer may contest such calculation by providing an alternative calculation to the Company in writing within thirty (30) calendar days of the Reinsurer’s 's receipt of the Company’s 's calculation. (d) If the Reinsurer contests the Company’s 's calculation, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s 's alternative calculation. If the parties reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s 's calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns for the preceding year. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. The parties to this Agreement agree to make the election set forth below DAC Tax Election pursuant to Section 1.848-2(g2(g)(8) (8) of the Income Tax Regulations issued effective December 29, 1992 under Section 848 of the CodeInternal Revenue Code of 1986, as amended. This election shall will be effective for taxable year 2016 at the inception of this Agreement and for all subsequent taxable years for which this Agreement remains in effect.. The terms used in this Section are defined in Regulation Section 1.848-2. The term “net consideration” will refer to either net consideration as defined in Section 1.848-2(f) or “gross premium and other consideration” as defined in Section 1.848-3(b), as appropriate. The following provisions will apply: (a) 5.1 The party with the Net Positive Consideration net positive consideration for this Agreement for each taxable year will capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1).; (b) Both 5.2 The parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year, or as year to ensure consistency. The parties also agree to exchange information otherwise required by the Internal Revenue Service, to ensure consistency.; (c) The Company 5.3 Each year you will submit a schedule to the Reinsurer us by May 1 of each year I with its your calculation of the net consideration for the preceding calendar year. The Reinsurer This schedule will be accompanied by a statement signed by an officer of the Company stating that you will report such net consideration in your tax return for the preceding calendar year; 5.4 We may contest such calculation calculations by providing an alternative calculation to you by May 31. If we do not so notify you, you will report the Company net consideration as determined by you in writing within thirty (30) your tax return for the previous calendar days year; and 5.5 If we contest your calculation of the Reinsurer’s receipt of the Company’s calculation. (d) If the Reinsurer contests the Company’s calculationnet consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s we submit our alternative calculation. If the parties reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of the net consideration, then the dispute each party shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes report such amount in their its respective income tax returns for the preceding year. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective previous calendar year. Each party represents and warrants that identifies this Agreement it is subject to United States taxation under either the provisions of subchapter L of Chapter 1 or the provisions of subpart F of subchapter N of Chapter 1 of the Internal Revenue Code of 1986, as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8)amended.

DAC Tax Election. The parties to this Agreement Ceding Company and Reinsurer hereby agree to make the following election set forth below pursuant to IRS Regulation Section 1.848-2(g) (8) of the Income Tax Regulations issued under 1.848‑2(g)(8), promulgated pursuant to Section 848 of the CodeInternal Revenue Code of 1986, as amended. This election shall be effective for taxable year 2016 2013 and for all subsequent taxable years for which this Reinsurance Agreement remains in effect. Both Parties agree to make the election by timely attaching to their tax returns to the schedule required by Section 1.848‑2(g)(8)(ii) of such Regulation. (a) 1. The party terms used in this Article are defined by reference to Regulation Section 1.848‑2 in effect on the date hereof. 2. The Party with the Net Positive Consideration net positive consideration for this Reinsurance Agreement for each taxable year will capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Reinsurance Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1). (b) 3. Both parties Parties agree to exchange information pertaining to the amount of net consideration under this Reinsurance Agreement each year, year to ensure consistency or as otherwise required by the Internal Revenue Service, to ensure consistency. (c) The 4. Ceding Company will submit a schedule to the Reinsurer by May 1 31 of each year with of its calculation of the net consideration for the preceding calendar year. The This schedule of calculations will be accompanied by a statement signed by an officer of Ceding Company stating that Ceding Company will report such net consideration in its tax return for the preceding calendar year. 5. Reinsurer may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) calendar days of the Reinsurer’s receipt of the Ceding Company’s calculation. If Reinsurer does not so notify Ceding Company, Reinsurer will report the net consideration as determined by Ceding Company in Reinsurer’s tax return for the previous calendar year. (d) 6. If the Reinsurer contests the Ceding Company’s calculationcalculation of the net consideration, the parties Parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s Reinsurer submits its alternative calculation. If the parties Ceding Company and Reinsurer reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute each Party shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes report such amount in their respective income tax returns for the preceding previous calendar year. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. All uncapitalized terms used in this Section 11.01 shall have the meanings set forth in the Treasury Regulations under section 848 of the Internal Revenue Code of 1986, as amended (the “Code”). (a) The parties hereby elect, pursuant to Treasury Regulations section 1.848-2(g)(8), to determine specified policy acquisition expenses with respect to this Agreement agree without regard to make the election set forth below pursuant to Section 1.848-2(ggeneral deductions limitation of section 848(c)(1) (8) of the Income Tax Regulations issued under Section 848 of the Code. This election shall be effective for taxable the calendar year 2016 ending on or after the Effective Time and for all subsequent taxable years for which any reinsurance agreement is deemed to exist due to an election made pursuant to this Section 11.01. Each party agrees to attach to its Tax Return filed for the first taxable year ending after this election becomes effective a schedule that identifies this Agreement remains in effect. (a) as the subject of this election. The party with the Net Positive Consideration for net positive consideration under this Agreement for each taxable year will shall capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section section 848(c)(1)) of the Code. (b) Both To ensure consistency, the parties agree to exchange information pertaining to the amount of net consideration under deemed to be paid pursuant to any reinsurance agreement deemed to exist due to an election made pursuant to this Agreement each year, or as otherwise required by the Internal Revenue Service, to ensure consistency. (c) Section 11.01. The Ceding Company will shall submit a schedule to the Reinsurer by May March 1 of each year with its calculation that follows a year during which this Agreement was in effect for any portion of such year of the Ceding Company’s calculations of the net consideration under this Agreement for the preceding calendar year. This schedule of calculations shall 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 federal income tax return for the preceding calendar year. The Reinsurer may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) calendar days of the Reinsurer’s receipt of the Ceding Company’s calculation. If the Reinsurer does not notify the Ceding Company within such time that it contests the calculation, the Reinsurer shall report the net consideration as determined by the Ceding Company in the Reinsurer’s Tax Return for the previous calendar year. (dc) If the Reinsurer contests the Ceding Company’s calculationcalculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s Reinsurer submits its alternative calculation. If the parties reach an agreement on the an amount of net consideration calculationconsideration, each party will report the agreed agreed-upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns for the preceding year. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending the previous calendar year. If during such period, the Ceding Company and the Reinsurer are unable to reach agreement, they shall within ten (10) days of the expiration of the thirty (30)-day period set forth in this Section 11.01(c), cause a Third Party Accountant promptly to review (which review shall commence no later than five (5) days after the election becomes effective that identifies selection of the Third Party Accountant) this Agreement and the calculations of the Ceding Company and the Reinsurer for the purpose of calculating the net consideration under this Agreement. In making such calculation, the Third Party Accountant shall consider adjustments to only those items or amounts in the Ceding Company’s calculation as to which the Reinsurer has disagreed. The Third Party Accountant shall deliver to the Ceding Company and the Reinsurer, as promptly as practicable (but no later than thirty (30) days after the commencement of its review), a reinsurance agreement for report setting forth such calculation, which joint elections have been made under Treasury Regulation calculation shall result in a net consideration between the amount thereof shown in the Ceding Company’s calculation delivered pursuant to Section 1.848-2(g)(811.01(b) and the amount thereof in the Reinsurer’s calculation delivered pursuant to Section 11.01(b). Such report shall be final and binding upon the Ceding Company and the Reinsurer. The fees of the Third Party Accountant shall be borne equally by the parties.

DAC Tax Election. All uncapitalized terms used in this Section 5.2 shall have the meanings set forth in the Treasury regulations under section 848 of the Internal Revenue Code of 1986, as amended (“Code”). (a) The parties Parties will elect, pursuant to Treasury regulations section 1.848-2(g)(8), to determine specified policy acquisition expenses with respect to this Agreement agree without regard to make the election set forth below pursuant to Section 1.848-2(ggeneral deductions limitation of section 848(c)(1) (8) of the Income Tax Regulations issued under Section 848 of the Code. This election shall be effective for taxable the calendar year 2016 ending on or after the Effective Date and for all subsequent taxable years for which any reinsurance agreement is deemed to exist due to an election made pursuant to Section 5.2 of this Agreement. Each Party agrees to attach to its Tax Return filed for the first taxable year ending after this election becomes effective a schedule that identifies this Agreement remains in effect. (a) as the subject of this election. The party Party with the Net Positive Consideration for net positive consideration under this Agreement for each taxable year will shall capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1section 848(c) (1) of the Code. (b) Both parties To ensure consistency, the Parties agree to exchange information pertaining to the amount of net consideration under deemed to be paid pursuant to any reinsurance agreement deemed to exist due to an election made pursuant to Section 5.2 of this Agreement each year, or as otherwise required by the Internal Revenue Service, to ensure consistency. (c) The Agreement. Ceding Company will shall submit a schedule to the Reinsurer by May March 1 of each year with its calculation that follows a year during which this Agreement was in effect for any portion of such year of Ceding Company’s calculations of the net consideration under this Agreement for the preceding calendar year. The This schedule of calculations shall be accompanied by a statement signed by an officer of Ceding Company stating that Ceding Company will report such net consideration in its federal income tax return for the preceding calendar year. Reinsurer may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) calendar days of the Reinsurer’s receipt of the Ceding Company’s calculation. If Reinsurer does not notify Ceding Company within such time that it contests the calculation, Reinsurer shall report the net consideration as determined by Ceding Company in Reinsurer’s Tax Return for the previous calendar year. (dc) If the Reinsurer contests the Ceding Company’s calculationcalculation of the net consideration, the parties Parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s Reinsurer submits its alternative calculation. If the parties Parties reach an agreement on the an amount of net consideration calculationconsideration, each party Party will report the agreed upon amount in its federal income tax return for the preceding previous calendar year. If the parties during such period, Ceding Company and Reinsurer are unable to reach an agreement on agreement, they shall within ten (10) days of the amount expiration of the thirty (30) day period set forth in this Section 5.2(c), cause a Third Party Accountant promptly to review (which review shall commence no later than five (5) days after the selection of the Third Party Accountant) this Agreement and the calculations of Ceding Company and Reinsurer for the purpose of calculating the net consideration, then the dispute shall be resolved pursuant to Article IX of consideration under this Agreement. If Reinsurer does not contest In making such calculation, the Third Party Accountant shall consider only those items or amounts in Ceding Company’s calculation as to which Reinsurer has disagreed. The Third Party Accountant shall deliver to Ceding Company and Reinsurer, as promptly as practicable (but no later than thirty (30) days after the parties will utilize commencement of its review), a report setting forth such calculation, which calculation shall result in a net consideration between the amount thereof shown in Ceding Company’s calculation provided delivered pursuant to Section 5.2(b) and the amount thereof in Reinsurer’s calculation delivered pursuant to Section 5.2(b). Such report shall be final and binding upon Ceding Company and Reinsurer. The fees, costs and expenses of the Third Party Accountant shall be borne (x) by Ceding Company if the difference between the net consideration as calculated by the Third Party Accountant and Ceding Company’s calculation is greater than the difference between the net consideration as calculated by the Third Party Accountant and Reinsurer’s calculation; (y) by Reinsurer if the first such difference is less than the second such difference; and (z) otherwise equally by Ceding Company for reporting purposes in their respective income tax returns for the preceding yearand Reinsurer. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. The parties to this Agreement Ceding Company and the Reinsurer hereby elect and agree to make the election set forth below pursuant to under Treasury Regulations Section 1.848-2(g2(g)(8) as follows: (8) a) The Ceding Company and the Reinsurer will each attach a schedule to its federal income tax return for the first taxable year ending after the Effective Date that identifies this Agreement as a reinsurance agreement for which a joint election under Treasury Regulation Section 1.848-2(g)(8) has been made, and will otherwise file its respective federal income tax returns in a manner consistent with the provisions of Treasury Regulation Section 1.848-2 as in effect on the Income Tax Regulations issued date this Agreement is executed; (b) For each taxable year under this Agreement, the party hereto with the net positive consideration, as defined in the regulations promulgated under Section 848 of the Code. This election shall be effective for taxable year 2016 and for all subsequent taxable years for which this Agreement remains in effect. (a) The party with the Net Positive Consideration for this Agreement for each taxable year , will capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1).) of the Code; (bc) Both parties The Ceding Company and the Reinsurer agree to exchange information pertaining to the amount of net consideration under this Agreement each year, year to ensure consistency or as otherwise required by the Internal Revenue Service, to ensure consistency.Code and applicable Treasury Regulations; (cd) The Company first tax year for which this election is effective is the taxable year ending December 31, 2019 (the “Effective Tax Year”); (e) The Reinsurer will submit a schedule to the Reinsurer Ceding Company by May 1 of 15 each year with its calculation of the amount of the net consideration for the preceding calendar year. This schedule of calculations will be accompanied by a statement that the Reinsurer will report such amount of net consideration in its tax return for the preceding calendar year; (f) The Reinsurer Ceding Company may contest such calculation by providing an alternative calculation to the Company Reinsurer in writing within thirty (30) calendar days of the ReinsurerCeding Company’s receipt of the Reinsurer’s calculation. If the Ceding Company does not so notify the Reinsurer, the Ceding Company will report the amount of net consideration as determined by the Reinsurer in the Ceding Company’s calculation.tax return for the previous calendar year; (dg) If the Reinsurer Ceding Company contests the CompanyReinsurer’s calculationcalculation of the amount of net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that on which the Ceding Company receives the Reinsurer’s submits its alternative calculation. If Both the parties reach an agreement on Ceding Company and the net consideration calculation, each party will report Reinsurer are subject to U.S. taxation under Subchapter L of Chapter 1 of the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns for the preceding yearCode. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. Section 12.1 The parties Company and the Reinsurer each acknowledge that it is subject to U.S. taxation under Subchapter “L” of the Internal Revenue Code of 1986 (as amended). Section 12.2 With respect to this Agreement Agreement, the Company and the Reinsurer elect and agree to make the election set forth below following pursuant to Section 1.848-2(g2(g)(8) (8) of the Income Tax Regulations issued December 1992 whereby: (i) Each party agrees to attach a schedule to its federal income tax return which identifies this Agreement for which the joint election under the regulation has been made; (ii) The party with net positive consideration (as defined in the regulations promulgated under Section 848 of the Code. This election shall be effective for taxable year 2016 and for all subsequent taxable years for which this Agreement remains in effect. (aInternal Revenue Code of 1986, as amended) The party with the Net Positive Consideration for this Agreement for each taxable year will agrees to capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1).; (biii) Both parties agree Each party agrees to exchange information pertaining to the amount of net consideration under this Agreement each year, year to ensure consistency or as otherwise required by the Internal Revenue Service, to ensure consistencyCode and applicable Treasury Regulations; and (iv) This election shall be effective for the taxable year that this Agreement was entered into and for all subsequent years that this Agreement remains in effect. (cv) The Company Reinsurer will submit a schedule to the Reinsurer Company by May April 1 of each year with its calculation of the net consideration for the preceding calendar year. The Reinsurer Company may contest such calculation by providing an alternative calculation to the Company Reinsurer in writing within thirty forty-five (3045) calendar days of the ReinsurerCompany’s receipt of the CompanyReinsurer’s calculation. (dvi) If the Reinsurer Company contests the CompanyReinsurer’s calculation, the parties Parties will act in good faith to reach an agreement as to the correct amount within thirty forty-five (3045) calendar days of the date that the Company Reinsurer receives the ReinsurerCompany’s alternative calculation. If the parties reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties Parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX XI of this Agreement. If Reinsurer the Company does not contest the CompanyReinsurer’s calculation calculation, the parties Parties will utilize the calculation provided by the Company Reinsurer for reporting purposes in their respective income tax returns for the preceding year. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. The parties to this Agreement agree to make the election set forth below pursuant to Section 1.848-2(g) (8) of the Income Tax Regulations issued under Section 848 of the Internal Revenue Code of 1986, as amended (the "Code"). This election shall be effective for taxable year 2016 2013 and for all subsequent taxable years for which this Agreement remains in effect. (a) The party with the Net Positive Consideration for this Agreement for each taxable year will capitalize Specified Policy Acquisition Expenses with respect to this Agreement without regard to the General Deductions Limitation of Code Section CodeSection 848(c)(1). (b) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year, or as otherwise required by the Internal Revenue Service, to ensure consistency. (c) The Company will submit a schedule to the Reinsurer by May 1 of each year with its calculation of the net consideration for the preceding calendar year. This schedule will be accompanied by a statement signed by an officer of the Company attesting to the calculation contained in said schedule. The Reinsurer may contest such calculation by providing an alternative calculation to the Company in writing within thirty (30) calendar days of the Reinsurer’s 's receipt of the Company’s 's calculation. (d) If the Reinsurer contests the Company’s 's calculation, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s 's alternative calculation. If the parties reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s 's calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns for the preceding year. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. The parties Parties shall elect, pursuant to Treasury Regulations Section 1.848-2(g)(8), to determine specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848(c)(1) of the Code. The Parties to this Agreement agree to make the election set forth below following provisions pursuant to Treasury Regulations Section 1.848-2(g2(g)(8): (a) (8) of the Income Tax The terms “Net Positive Consideration,” “Specified Policy Acquisition Expenses” and “General Deductions Limitation” used in this Article are defined by reference to Treasury Regulations issued under Section 1.848-2 and Section 848 of the Code. This election shall be effective for taxable year 2016 and for all subsequent taxable years for which this Agreement remains in effect.; (ab) The party Party with the Net Positive Consideration for this Agreement for each taxable year will shall capitalize Specified Policy Acquisition Expenses with respect to this Agreement without regard to the General Deductions Limitation of Code Section 848(c)(1).) the Code; (bc) The election shall be effective for the calendar year ending on or after the Effective Date and for all subsequent taxable years for which this Agreement is in effect; and (d) Both parties Parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year, or as otherwise required by the Internal Revenue Service, to ensure consistency.. The method and timing of the exchange of such information will be as follows: (ci) The Ceding Company will shall submit a schedule report to the Reinsurer by May 1 of each year with its calculation of the net consideration for the preceding calendar year. If the Reinsurer accepts the Ceding Company’s calculation, it shall report such net consideration in its tax return for the previous calendar year. (ii) The Reinsurer may contest such calculation by providing an alternative calculation to the Company Ceding Company, in writing writing, within thirty (30) calendar 30 days of the Reinsurer’s receipt of the Company’s calculation. (d) If the Reinsurer contests the Company’s calculation, the parties will . The Parties shall act in good faith to resolve the discrepancy in a manner acceptable to both Parties within 30 days of the date the Reinsurer submits its alternative calculation. If the Parties reach an agreement as to the correct amount within thirty (30) calendar days calculation of the date that the Company receives the Reinsurer’s alternative calculation. If the parties reach an agreement on the net consideration, each Party shall report such net consideration calculation, each party will report the agreed upon amount in its income respective tax return for the preceding previous calendar year. . (iii) If the parties Ceding Company and the Reinsurer are unable to reach agreement, they shall within 10 days of the expiration of the 30 day period set forth in this Section 15.1 cause an agreement on independent accounting firm to promptly review this Agreement and the amount calculations of the Ceding Company and the Reinsurer for the purpose of calculating the net consideration, then the dispute shall be resolved pursuant to Article IX of consideration under this Agreement. If Reinsurer does not contest In making such calculation, the independent accounting firm shall consider only those items or amounts in the Ceding Company’s calculation as to which the parties will utilize Reinsurer has disagreed. The independent accounting firm shall deliver to the Ceding Company and Reinsurer, within 30 days or as promptly as practicable, a report setting forth such calculation, which calculation provided shall result in a net consideration between the amount thereof shown in the Ceding Company’s calculation delivered pursuant to this Section and the amount thereof in Reinsurer’s calculation delivered pursuant to this Section. Such report shall be final and binding upon the Ceding Company and the Reinsurer. The fees, costs and expenses of the independent accounting firm shall be borne (a) by the Ceding Company for reporting purposes in their respective income tax returns for if the preceding yeardifference between the net consideration as calculated by the independent accounting firm and Ceding Company’s calculation is greater than the difference between the net consideration as calculated by the independent accounting firm and the Reinsurer’s calculation; (b) by the Reinsurer if the first such difference is less than the second such difference; and (c) otherwise equally by the Ceding Company and the Reinsurer. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. The parties In regards to this Agreement the Reinsured Policies described in Exhibit A, Ceding Company and Reinsurer agree to make the election set forth below following pursuant to United States Treasury Regulation Section 1.848-2(g) (8) of the Income Tax Regulations issued under Section 848 of the Code. This election shall be effective for taxable year 2016 and for all subsequent taxable years for which this Agreement remains in effect.2(g)(8): (a) The term “party” will refer to either Ceding Company or Reinsurer as appropriate. (b) The terms used in this Section are defined by reference to United States Treasury Regulation Section 1.848-1 and 1.848-2 as in effect on the Effective Date and at all relevant times thereafter. The term "net consideration" refers to net consideration as defined in Regulation Section 1.848-2(f). (c) For each taxable year ending on or after the Effective Date, the party with the Net Positive Consideration for net positive consideration under this Agreement for each taxable year will capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1)) of the Internal Revenue Code of 1986, as amended, and Treasury Regulations promulgated thereunder. (bd) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year, year to ensure consistency or as otherwise required by the United States Internal Revenue Service, to ensure consistency. (ce) The Company exchange of information will follow the following procedure: By May 1 of each year, Reinsurer will submit a schedule to the Reinsurer by May 1 Ceding Company of each year with its calculation of the net consideration for the preceding calendar taxable year. The This schedule of calculations will be accompanied by a statement signed by an officer of Reinsurer may contest such calculation by providing an alternative calculation to stating the amount of net consideration Reinsurer will report in its tax return for the preceding taxable year. To ensure consistency, Ceding Company will utilize this information in writing within thirty (30) calendar days of determining its net consideration for its preceding taxable year. Ceding Company shall advise Reinsurer if it disagrees with the Reinsurer’s receipt of the Company’s calculation. (d) If the Reinsurer contests the Company’s calculation, calculations provided and the parties will agree to act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s alternative calculation. If the parties reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns for the preceding yearresolve such differences amicably. (ef) Each party will Both parties agree to attach a schedule to its federal income tax return their respective Federal Income Tax Return for its first the taxable year ending after in which the election becomes effective that Effective Date occurs, which identifies this the Agreement as a reinsurance agreement for which the joint elections have been made election under Treasury Regulation Section 1.848-2(g)(8) has been made. (g) Both parties warrant that they are U.S. taxpayers as defined by United States Treasury Regulation 1.848-2(h)(2)(ii).

DAC Tax Election. The parties to this Agreement Company and the Reinsurer hereby agree to make the election set forth below following pursuant to Section 1.848-2(g2(g)(8) (8) of the Income Tax Regulations issued December 1992 (as amended, supplemented or corrected and in effect as of the effective date of this Agreement, the “Regulations”) under Section 848 of the Internal Revenue Code of 1986, as amended (the “Code”). This election shall be effective for taxable year 2016 2000 and for all subsequent taxable years for which this Agreement remains in effect. (a) 1. The term “party” will refer to either the Company or the Reinsurer, as appropriate. 2. The terms used in this Article are defined by reference to Section 1.848-2 of the Regulations. 3. The party with the Net Positive Consideration net positive consideration for this Agreement for each taxable year will capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1)848(c)(l) of the Code. (b) 4. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year, year to ensure consistency or as otherwise required by the Internal Revenue Service, to ensure consistency. (c) 5. The Company will submit a schedule to the Reinsurer by May 1 of each year with of 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 Company stating that the Company will report such net consideration in its tax return for the preceding calendar year. 6. The Reinsurer may contest such calculation by providing an alternative calculation to the Company in writing within thirty (30) calendar 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. (d) 7. If the Reinsurer contests the Company’s calculationcalculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s Reinsurer submits its alternative calculation. If the parties Company and the Reinsurer reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute each party shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes report such amount in their respective income tax returns for the preceding previous calendar year. (e) Each party will attach a schedule 8. Both parties agree to its federal income tax return for its first taxable year ending after make the election becomes effective that identifies contemplated by this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Article 27 by timely attaching to their tax returns the schedule required by Section 1.848-2(g)(8)2(g)(8)(ii) of the Regulations. 5. Effective as of January 1, 2000, the Reinsurance Agreement shall be amended by adding an Article 28 thereto as follows:

DAC Tax Election. The parties to this Agreement agree to make the election set forth below pursuant to Section 1.848-2(g) (8) of the Income Tax Regulations issued under Section 848 of the Code. This election shall be effective for taxable year 2016 and for all subsequent taxable years for which this Agreement remains in effect. (a) The party with the Net Positive Consideration for this Agreement for each taxable year will capitalize Specified Policy Acquisition Expenses with respect to this Agreement without regard to the General Deductions Limitation of Code Section 848(c)(1). (b) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year, or as otherwise required by the Internal Revenue Service, to ensure consistency. (c) The Company will submit a schedule to the Reinsurer by May 1 of each year with its calculation of the net consideration for the preceding calendar year. The Reinsurer may contest such calculation by providing an alternative calculation to the Company in writing within thirty (30) calendar days of the Reinsurer’s 's receipt of the Company’s 's calculation. (d) If the Reinsurer contests the Company’s 's calculation, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s 's alternative calculation. If the parties reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s 's calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns for the preceding year. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).. ARTICLE XV

DAC Tax Election. The parties to this Agreement agree to make the election set forth below DAC Tax Election pursuant to Section 1.848-2(g2(g)(8) (8) of the Income Tax Regulations issued effective December 29, 1992 under Section 848 of the CodeInternal Revenue Code of 1986, as amended. This election shall will be effective for taxable year 2016 at the inception of this Agreement and for all subsequent taxable years for which this Agreement remains in effect.. The terms used in this Section are defined in Regulation Section 1.848-2. The term “net consideration” will refer to either net consideration as defined in Section 1.848-2(f) or “gross premium and other consideration” as defined in Section 1.848-3(b), as appropriate. The following provisions will apply: (a) 5.1 The party with the Net Positive Consideration net positive consideration for this Agreement for each taxable year will capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1).; (b) Both 5.2 The parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year, or as year to ensure consistency. The parties also agree to exchange information otherwise required by the Internal Revenue Service, to ensure consistency.; (c) The Company 5.3 Each year you will submit a schedule to the Reinsurer us by May 1 of each year I with its your calculation of the net consideration for the preceding calendar year. The Reinsurer This schedule will be accompanied by a statement signed by an officer of the Company stating that you will report such net consideration in your tax return for the preceding calendar year; SCOR — CIA Life Treat Eff 1-1-09 FINAL 5.4 We may contest such calculation calculations by providing an alternative calculation to you by May 31. If we do not so notify you, you will report the Company net consideration as determined by you in writing within thirty (30) your tax return for the previous calendar days year; and 5.5 If we contest your calculation of the Reinsurer’s receipt of the Company’s calculation. (d) If the Reinsurer contests the Company’s calculationnet consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s we submit our alternative calculation. If the parties reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of the net consideration, then the dispute each party shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes report such amount in their its respective income tax returns for the preceding year. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective previous calendar year. Each party represents and warrants that identifies this Agreement it is subject to United States taxation under either the provisions of subchapter L of Chapter 1 or the provisions of subpart F of subchapter N of Chapter 1 of the Internal Revenue Code of 1986, as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8)amended.

DAC Tax Election. The parties to this Agreement agree to make the election set forth below pursuant to Section 1.848-2(g2(g)(8) (8) of the Income Tax Regulations issued under Section 848 of the Internal Revenue Code of 1986, as amended (the “Code”). This election shall be effective for taxable year 2016 2009 and for all subsequent taxable years for which this Agreement remains in effect. (a) The party with the Net Positive Consideration for this Agreement for each taxable year will capitalize Specified Policy Acquisition Expenses with respect to this Agreement without regard to the General Deductions Limitation of Code Section 848(c)(1). (b) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year, or as otherwise required by the Internal Revenue Service, to ensure consistency. (c) The Company will submit a schedule to the Reinsurer by May 1 of each year with its calculation of the net consideration for the preceding calendar year. This schedule will be accompanied by a statement signed by an officer of the Company attesting to the calculation contained in said schedule. The Reinsurer may contest such calculation by providing an alternative calculation to the Company in writing within thirty (30) calendar days of the Reinsurer’s receipt of the Company’s calculation. (d) If the Reinsurer contests the Company’s calculation, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s alternative calculation. If the parties reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX XII of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns for the preceding year. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. The parties to this Agreement Company and the Reinsurer hereby agree to make the election set forth below following pursuant to Section 1.848-2(g2(g)(8) (8) of the Income Tax Regulations issued December 1992 (as amended, supplemented or corrected and in effect as of the effective date of this Agreement, the “Regulations”) under Section 848 of the Internal Revenue Code of 1986, as amended (the “Code”). This election shall be effective for taxable year 2016 1999 and for all subsequent taxable years for which this Agreement remains in effect. (a) 1. The term “party” will refer to either the Company or the Reinsurer, as appropriate. 2. The terms used in this Article are defined by reference to Section 1.848-2 of the Regulations. 3. The party with the Net Positive Consideration net positive consideration for this Agreement for each taxable year will capitalize Specified Policy Acquisition Expenses specified policy acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1)848(c)(l) of the Code. (b) 4. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year, year to ensure consistency or as otherwise required by the Internal Revenue Service, to ensure consistency. (c) 5. The Company will submit a schedule to the Reinsurer by May 1 of each year with of 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 Company stating that the Company will report such net consideration in its tax return for the preceding calendar year. 6. The Reinsurer may contest such calculation by providing an alternative calculation to the Company in writing within thirty (30) calendar 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. (d) 7. If the Reinsurer contests the Company’s calculationcalculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s Reinsurer submits its alternative calculation. If the parties Company and the Reinsurer reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute each party shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes report such amount in their respective income tax returns for the preceding previous calendar year. (e) Each party will attach a schedule 8. Both parties agree to its federal income tax return for its first taxable year ending after make the election becomes effective that identifies contemplated by this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Article 27 by timely attaching to their tax returns the schedule required by Section 1.848-2(g)(8)2(g)(8)(ii) of the Regulations.

DAC Tax Election. The parties to this Agreement agree to make the election set forth below pursuant to Section 1.848-2(g2(g)(8) (8) of the Income Tax Regulations issued under Section 848 of the Internal Revenue Code of 1986, as amended (the “Code”). This election shall be effective for taxable year 2016 2010 and for all subsequent taxable years for which this Agreement remains in effect. (a) The party with the Net Positive Consideration for this Agreement for each taxable year will capitalize Specified Policy Acquisition Expenses with respect to this Agreement without regard to the General Deductions Limitation of Code Section 848(c)(1). (b) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year, or as otherwise required by the Internal Revenue Service, to ensure consistency. (c) The Company will submit a schedule to the Reinsurer by May 1 of each year with its calculation of the net consideration for the preceding calendar year. This schedule will be accompanied by a statement signed by an officer of the Company attesting to the calculation contained in said schedule. The Reinsurer may contest such calculation by providing an alternative calculation to the Company in writing within thirty (30) calendar days of the Reinsurer’s receipt of the Company’s calculation. (d) If the Reinsurer contests the Company’s calculation, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s alternative calculation. If the parties reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX XII of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns for the preceding year. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).

DAC Tax Election. The parties In regards to this Agreement the Reinsured Contracts described in Exhibit A, Ceding Company and Reinsurer agree to make the election set forth below following pursuant to United States Treasury Regulation Section 1.848-2(g) (8) of the Income Tax Regulations issued under Section 848 of the Code. This election shall be effective for taxable year 2016 and for all subsequent taxable years for which this Agreement remains in effect.2(g)(8): (a) The term “party” will refer to either Ceding Company or Reinsurer as appropriate. (b) The terms used in this Section are defined by reference to United States Treasury Regulation Section 1.848-1 and 1.848-2 as in effect on the Effective Date and at all relevant times thereafter. The term "net consideration" refers to net consideration as defined in Regulation Section 1.848-2(f). (c) For each taxable year ending on or after the Effective Date, the party with the Net Positive Consideration for net positive consideration under this Agreement for each taxable year will capitalize Specified Policy Acquisition Expenses specified contract acquisition expenses with respect to this Agreement without regard to the General Deductions Limitation general deductions limitation of Code Section 848(c)(1)) of the Internal Revenue Code of 1986, as amended, and Treasury Regulations promulgated thereunder. (bd) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year, year to ensure consistency or as otherwise required by the United States Internal Revenue Service, to ensure consistency. (ce) The Company exchange of information will follow the following procedure: By May 1 of each year, Reinsurer will submit a schedule to the Reinsurer by May 1 Ceding Company of each year with its calculation of the net consideration for the preceding calendar taxable year. The This schedule of calculations will be accompanied by a statement signed by an officer of Reinsurer may contest such calculation by providing an alternative calculation to stating the amount of net consideration Reinsurer will report in its tax return for the preceding taxable year. To ensure consistency, Ceding Company will utilize this information in writing within thirty (30) calendar days of determining its net consideration for its preceding taxable year. Ceding Company shall advise Reinsurer if it disagrees with the Reinsurer’s receipt of the Company’s calculation. (d) If the Reinsurer contests the Company’s calculation, calculations provided and the parties will agree to act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date that the Company receives the Reinsurer’s alternative calculation. If the parties reach an agreement on the net consideration calculation, each party will report the agreed upon amount in its income tax return for the preceding calendar year. If the parties are unable to reach an agreement on the amount of net consideration, then the dispute shall be resolved pursuant to Article IX of this Agreement. If Reinsurer does not contest the Company’s calculation the parties will utilize the calculation provided by the Company for reporting purposes in their respective income tax returns for the preceding yearresolve such differences amicably. (ef) Each party will Both parties agree to attach a schedule to its federal income tax return their respective Federal Income Tax Return for its first the taxable year ending after in which the election becomes effective that Effective Date occurs, which identifies this the Agreement as a reinsurance agreement for which the joint elections have been made election under Treasury Regulation Section 1.848-2(g)(8) has been made. (g) Both parties warrant that they are U.S. taxpayers as defined by United States Treasury Regulation 1.848-2(h)(2)(ii).

DAC Tax Election. The parties Parties shall elect, pursuant to Treasury Regulations Section 1.848-2(g)(8), to determine specified policy acquisition expenses with respect to this Agreement without regard to the general deductions limitation of Section 848(c)(1) of the Code. The Parties to this Agreement agree to make the election set forth below following provisions pursuant to Treasury Regulations Section 1.848-2(g2(g)(8): (a) (8) of the Income Tax The terms “Net Positive Consideration,” “Specified Policy Acquisition Expenses” and “General Deductions Limitation” used in this Article are defined by reference to Treasury Regulations issued under Section 1.848-2 and Section 848 of the Code. This election shall be effective for taxable year 2016 and for all subsequent taxable years for which this Agreement remains in effect.; (ab) The party Party with the Net Positive Consideration for this Agreement for each taxable year will shall capitalize Specified Policy Acquisition Expenses with respect to this Agreement without regard to the General Deductions Limitation of Code Section 848(c)(1).) the Code; (bc) The election shall be effective for the calendar year ending on or after the Effective Date and for all subsequent taxable years for which this Agreement is in effect; and (d) Both parties Parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year, or as otherwise required by the Internal Revenue Service, to ensure consistency.. The method and timing of the exchange of such information will be as follows: (ci) The Ceding Company will shall submit a schedule report to the Reinsurer by May 1 of each year with its calculation of the net consideration for the preceding calendar year. If the Reinsurer accepts the Ceding Company’s calculation, it shall report such net consideration in its tax return for the previous calendar year. (ii) The Reinsurer may contest such calculation by providing an alternative calculation to the Company Ceding Company, in writing writing, within thirty (30) calendar 30 days of the Reinsurer’s receipt of the Company’s calculation. (d) If the Reinsurer contests the Company’s calculation, the parties will . The Parties shall act in good faith to resolve the discrepancy in a manner acceptable to both Parties within 30 days of the date the Reinsurer submits its alternative calculation. If the Parties reach an agreement as to the correct amount within thirty (30) calendar days calculation of the date that the Company receives the Reinsurer’s alternative calculation. If the parties reach an agreement on the net consideration, each Party shall report such net consideration calculation, each party will report the agreed upon amount in its income respective tax return for the preceding previous calendar year. . (iii) If the parties Ceding Company and the Reinsurer are unable to reach agreement, they shall within 10 days of the expiration of the 30 day period set forth in this Section 15.1 cause an agreement on independent accounting firm to promptly review this Agreement and the amount calculations of the Ceding Company and the Reinsurer for the purpose of calculating the net consideration, then the dispute shall be resolved pursuant to Article IX of consideration under this Agreement. If Reinsurer does not contest In making such calculation, the independent accounting firm shall consider only those items or amounts in the Ceding Company’s calculation as to which the parties will utilize Reinsurer has disagreed or those items in the Reinsurer’s calculation provided for which there is no item or amount to which to compare in the Ceding Company’s calculation. The independent accounting firm shall deliver to the Ceding Company and Reinsurer, within 30 days or as promptly as practicable, a report setting forth such calculation, which calculation shall result in a net consideration between the amount thereof shown in the Ceding Company’s calculation delivered pursuant to this Section and the amount thereof in Reinsurer’s calculation delivered pursuant to this Section. Such report shall be final and binding upon the Ceding Company and the Reinsurer. The fees, costs and expenses of the independent accounting firm shall be borne (a) by the Ceding Company for reporting purposes in their respective income tax returns for if the preceding yeardifference between the net consideration as calculated by the independent accounting firm and Ceding Company’s calculation is greater than the difference between the net consideration as calculated by the independent accounting firm and the Reinsurer’s calculation; (b) by the Reinsurer if the first such difference is less than the second such difference; and (c) otherwise equally by the Ceding Company and the Reinsurer. (e) Each party will attach a schedule to its federal income tax return for its first taxable year ending after the election becomes effective that identifies this Agreement as a reinsurance agreement for which joint elections have been made under Treasury Regulation Section 1.848-2(g)(8).