Common use of DAC TAX Clause in Contracts

DAC TAX. SECTION 1.848-2(G(8) ELECTION 1. The term "party" will refer to either the Reinsured or the Reinsurer as appropriate. 2. The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect December 1992. 3. 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 Section 848(c)(1). 4. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency or is otherwise required by the Internal Revenue Service. 5. The Reinsured will submit a schedule to the Reinsurer by May 1 of each year 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 Reinsured stating that the Reinsured 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 Reinsured in writing within thirty days of the Reinsurer's receipt of the Reinsured's calculation. If the Reinsurer does not so notify the Reinsured, the Reinsurer will report the net consideration as determined by the Reinsured in the Reinsurer's tax return for the previous calendar year. 7. If the Reinsurer contests the Reinsured' s calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured and the Reinsurer reach agreement on an amount of net consideration, each party shall report such amount in their respective tax returns for the previous calendar year.

DAC TAX. SECTION 1.848The Parties to this Agreement agree to the following provisions pursuant to Section 1,848-2(G(82(g)(8) ELECTIONof the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. a. The term "party" will refer to either the Reinsured or the Reinsurer as appropriate. 2. The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect December 1992. 3. The party 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 Section 848(c)(1). 4. b. Both parties Parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. c. The Reinsured Company will submit a schedule to the Reinsurer by May 1 of each year of with 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 Reinsured stating that the Reinsured 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 Reinsured Company in writing within thirty (30) days of the Reinsurer's ’s receipt of the Reinsured's Company’s calculation. If the Reinsurer does not so notify the ReinsuredCompany within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Company in the Reinsurer's ’s tax return for the previous calendar year. 7. d. If the Reinsurer contests the Reinsured' s Company’s calculation of the net consideration, the parties Parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall Party will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. e. Both the Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended.

DAC TAX. SECTION 14.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(G(82(g)(8) ELECTIONof the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. (a) The term "'party" will refer ' refers to either the Reinsured Ceding Company or the Reinsurer REINSURER, as appropriate. 2. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992. 3. (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 Section 848(c)(1). 4. (b) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. (c) The Reinsured Ceding Company will submit a schedule to the Reinsurer REINSURER by May April 1 of each year of with 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 Reinsured Ceding Company stating that the Reinsured Ceding Company will report such net consideration in its tax return for the preceding calendar year. 6. The Reinsurer REINSURER may contest such calculation by providing an alternative calculation to the Reinsured Ceding Company in writing within thirty (30) days of the ReinsurerREINSURER's receipt of the ReinsuredCeding Company's calculation. If the Reinsurer REINSURER does not so notify the ReinsuredCeding Company within the required timeframe, the Reinsurer REINSURER will report the net consideration as determined by the Reinsured Ceding Company in the ReinsurerREINSURER's tax return for the previous calendar year. 7. If the Reinsurer contests the Reinsured' s calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured and the Reinsurer reach agreement on an amount of net consideration, each party shall report such amount in their respective tax returns for the previous calendar year.

DAC TAX. SECTION 14.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(G(82(g) ELECTION(8) of the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. (a) The term "`party" will refer ' refers to either the Reinsured Ceding Company or the Reinsurer Reinsurer, as appropriate. 2. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992. 3. (c) 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 Section 848(c)(1). 4. (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. (e) The Reinsured Ceding Company will submit a schedule to the Reinsurer by May April 1 of each year of with 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 Reinsured Ceding Company stating that the Reinsured Ceding 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 Reinsured Ceding company in writing within thirty (30) days of the Reinsurer's receipt of the ReinsuredCeding Company's calculation. If the Reinsurer does not so notify the ReinsuredCeding Company within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Ceding Company in the Reinsurer's tax return for the previous calendar year. 7. (f) If the Reinsurer contests the Reinsured' s Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Ceding Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended. IDSL-NY Succession Select Treaty

DAC TAX. SECTION The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(G(82(g)(8) ELECTIONof the Income Tax Regulations effective December 29,1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. a. The term "“party" will refer ” refers to either the Reinsured Company or the Reinsurer Reinsurer, as appropriate. 2. b. The terms used in In this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992. 3. c. 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 Section 848(c)(1). 4. d. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. e. The Reinsured Company will submit a schedule of calculations to the Reinsurer by May 1 of each year of with 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 Reinsured stating that the Reinsured 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 Reinsured Company in writing within thirty (30) days of the Reinsurer's ’s receipt of the Reinsured's Company’s calculation. If the Reinsurer does not so notify the ReinsuredCompany within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Company in the Reinsurer's ’s tax return for the previous calendar year. 7. f. If the Reinsurer contests the Reinsured' s Company’s calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. g. Both the Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended.

DAC TAX. SECTION 1.848-2(G(814.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848- 2(g)(8) ELECTIONof the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. (a) The term "`party" will refer ' refers to either the Reinsured Ceding Company or the Reinsurer Reinsurer, as appropriate. 2. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992. 3. (c) 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 Section 848(c)(1). 4. (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. (e) The Reinsured Ceding Company will submit a schedule to the Reinsurer by May April 1 of each year of with 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 Reinsured Ceding Company stating that the Reinsured Ceding 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 Reinsured Ceding Company in writing within thirty (30) days of the Reinsurer's receipt of the ReinsuredCeding Company's calculation. If the Reinsurer does not so notify advise the ReinsuredCeding Company within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Ceding Company in the Reinsurer's tax return for the previous calendar year. 7. (f) If the Reinsurer contests the Reinsured' s Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Ceding Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended. IDSL-NY VUL4/LP Select Treaty 24

DAC TAX. SECTION 1.848-2(G(814.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848- 2(g)(8) ELECTIONof the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. (a) The term "'party" will refer ' refers to either the Reinsured Ceding Company or the Reinsurer Reinsurer, as appropriate. 2. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992. 3. (c) 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 Section 848(c)(1). 4. (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. (e) The Reinsured Ceding Company will submit a schedule to the Reinsurer by May April 1 of each year of with 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 Reinsured Ceding Company stating that the Reinsured Ceding 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 Reinsured Ceding Company in writing within thirty (30) days of the Reinsurer's receipt of the ReinsuredCeding Company's calculation. If the Reinsurer does not so notify advise the ReinsuredCeding Company within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Ceding Company in the Reinsurer's tax return for the previous calendar year. 7. (f) If the Reinsurer contests the Reinsured' s Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Ceding Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended. IDSL VUL4/LP Select Treaty 25

DAC TAX. TREASURY REGULATION SECTION 1.848-2(G(82(g)98) ELECTIONELECTION The CEDING COMPANY and the REINSURER hereby agree to the following pursuant to Section 1.848-2(g)(8) of the Income Tax Regulations issued December 29, 1992, under Section 848 of the Internal Revenue Code 1986, as amended. This election shall be effective for the year this Agreement becomes effective and all subsequent taxable years for which this Agreement remains in effect. 1. A. The term "party" will refer to either the Reinsured CEDING COMPANY or the Reinsurer REINSURER as appropriate. 2. B. The terms used in this Article are defined by reference to Regulation Treasury Regulations Section 1.848-2 in effect as of December 29, 1992. 3. C. 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 deduction limitation of IRC Section 848(c)(1). 4. D. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency or is consistency. The parties also agree to exchange information, which may be otherwise required by the Internal Revenue ServiceIRS. 5. E. The Reinsured CEDING COMPANY will submit to the REINSURER by April 1st of each year, a schedule to the Reinsurer by May 1 of each year 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 Reinsured CEDING COMPANY stating that the Reinsured CEDING COMPANY will report such net consideration in its tax return for the preceding calendar year. 6. F. The Reinsurer REINSURER may contest such calculation by providing an alternative alternate calculation to the Reinsured CEDING COMPANY in writing within thirty (30) days of the ReinsurerREINSURER's receipt of the ReinsuredCEDING COMPANY's calculation. If the Reinsurer REINSURER does not so notify the ReinsuredCEDING COMPANY, the Reinsurer REINSURER will report the net consideration as determined by the Reinsured CEDING COMPANY in the ReinsurerREINSURER's tax return for the previous calendar year. 7. G. If the Reinsurer REINSURER contests the Reinsured' s CEDING COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer REINSURER submits its alternative alternate calculation. If the Reinsured REINSURER and the Reinsurer CEDING COMPANY reach agreement on an amount of net consideration, each party shall report such amount in their respective tax returns for the previous calendar year.

DAC TAX. SECTION The Company and the Reinsurer hereby agree to the following pursuant to Section 1.848-2(G(82(g)(8) ELECTIONof the Income Tax Regulations issued December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended. This election shall be effective for all taxable years for which this Agreement remains in effect. 1. A. The term "party" will refer to either the Reinsured Company or the Reinsurer Reinsurer, as appropriate. 2. B. The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect as of December 29, 1992. 3. C. The party with the net positive consideration for this Agreement for each taxable year will capitalize specified policy acquisition expenses expense with respect to this Agreement without regard to the general deductions limitation of Section 848(c)(1848 (c)(1). 4. Both parties D. The Company and the Reinsurer agree to exchange information pertaining to the amount of the net consideration under this Agreement each year to ensure consistency or is as otherwise required by the Internal Revenue Service. 5. E. The Reinsured Company will submit a schedule to the Reinsurer by May June 1 of each year 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 Reinsured Company stating that the Reinsured Company will report such net consideration in its tax return for the preceding calendar year. 6. F. The Reinsurer may contest such calculation by providing an alternative calculation to the Reinsured Company in writing within thirty (30) days of the Reinsurer's receipt of the ReinsuredCompany's calculation. If the Reinsurer does not so notify the ReinsuredCompany, the Reinsurer will report the net consideration as determined by the Reinsured Company in the Reinsurer's tax return for the previous calendar year. 7. G. If the Reinsurer contests the Reinsured' s Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Reinsurer and the Reinsurer Company reach agreement on an amount of net consideration, each party shall report such amount in their respective tax returns for the previous calendar year.

DAC TAX. SECTION DAC TAX 12.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(G(82(g)(8) ELECTIONof the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. a. The term "‘party" will refer ’ refers to either the Reinsured Ceding Company or the Reinsurer Reinsurer, as appropriate. 2. b. The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992. 3. c. 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 Section 848(c)(1). 4. d. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. e. The Reinsured Ceding Company will submit a schedule to the Reinsurer by May April 1 of each year of with its calculation of the net consideration for the preceding calendar year. year in the form attached in Exhibit E. This schedule of calculations will be accompanied by a statement signed by an officer of the Reinsured Ceding Company stating that the Reinsured Ceding 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 Reinsured Ceding Company in writing within thirty 45 days of the Reinsurer's ’s receipt of the Reinsured's Ceding Company’s calculation. If the Reinsurer does not so notify the ReinsuredCeding Company within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Ceding Company in the Reinsurer's ’s tax return for the previous calendar year. 7. f. If the Reinsurer contests the Reinsured' s Ceding Company’s calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Ceding Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. g. Both the Ceding Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended.

DAC TAX. SECTION 1.848-2(G(814.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848- 2(g)(8) ELECTIONof the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. (a) The term "'party" will refer ' refers to either the Reinsured Ceding Company or the Reinsurer Reinsurer, as appropriate. 2. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect effective December 29, 1992. 3. (c) 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 Section 848(c)(1). 4. (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. (e) The Reinsured Ceding Company will submit a schedule to the Reinsurer by May April 1 of each year of with 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 Reinsured Ceding Company stating that the Reinsured Ceding 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 Reinsured Ceding Company in writing within thirty (30) days of the Reinsurer's receipt of the ReinsuredCeding Company's calculation. If the Reinsurer does not so notify advise the ReinsuredCeding Company within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Ceding Company in the Reinsurer's tax return for the previous calendar year. 7. (f) If the Reinsurer contests the Reinsured' s Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Ceding Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended.

DAC TAX. SECTION The Company and Life Re hereby agree to make an election pursuant to Section 1.848-2(G(82(g)(8) ELECTIONof the Income Tax Regulations issued December 1992, under Section 848 of the Internal Revenue Code of 1986, as amended. This election shall be effective for 1993 and for all subsequent taxable years for which this Agreement remains in effect. The Company and Life Re also agree to the following: 1. (a) The term "party" will refer to either the Reinsured or the Reinsurer Company of Life Re as appropriate. 2. (b) The terms used use in this Article are defined by reference to Regulation Section 1.848-2 in effect December 1992. 3. (c) 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 Section 848(c)(1). 4. (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency or is otherwise required by the Internal Revenue Service. 5. (e) The Reinsured Company will submit a schedule to the Reinsurer Life Re by May 1 of each year 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 Reinsured Company stating that the Reinsured Company will report such net consideration in its tax return for the preceding calendar year. 6. The Reinsurer (f) Life Re may contest such calculation by providing an alternative calculation to the Reinsured Company in writing within thirty (30) days of the ReinsurerLife Re's receipt of the ReinsuredCompany's calculation. If the Reinsurer Life Re does not so notify the ReinsuredCompany, the Reinsurer Life Re will report the net consideration as determined by the Reinsured Company in the ReinsurerLife Re's tax return for the previous calendar year. 7. (g) If the Reinsurer Life Re contests the Reinsured' s Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer Life Re submits its alternative calculation. If the Reinsured Company and the Reinsurer Life Re reach agreement on an amount of net consideration, each party shall report such amount in their respective tax returns for the previous calendar year.

DAC TAX. SECTION 14.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(G(82(g)(8) ELECTIONof the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. (a) The term "`party" will refer ' refers to either the Reinsured Ceding Company or the Reinsurer Reinsurer, as appropriate. 2. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992. 3. (c) 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 Section 848(c)(1). 4. (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. (e) The Reinsured Ceding Company will submit a schedule to the Reinsurer by May April 1 of each year of with 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 Reinsured Ceding Company stating that the Reinsured Ceding 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 Reinsured Ceding Company in writing within thirty (30) days of the Reinsurer's receipt of the ReinsuredCeding Company's calculation. If the Reinsurer does not so notify the ReinsuredCeding Company within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Ceding Company in the Reinsurer's tax return for the previous calendar year. 7. (f) If the Reinsurer contests the Reinsured' s Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Ceding Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended. IDS VUL JLLS Generic Master Treaty

DAC TAX. SECTION 1.848-2(G(8The Company and the Reinsurer hereby agree to the following pursuant to Section 1.848­2(g)(8) ELECTIONof the Income Tax Regulations issued December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended. This election shall be effective for all taxable years for which this Agreement remains in effect. 1. The term "partyParty" will shall refer to either the Reinsured Company or the Reinsurer Reinsurer, as appropriate. 2. The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect as of December 29, 1992. 3. The party Party with the net positive consideration for this Agreement for each taxable year will shall capitalize specified policy acquisition expenses expense with respect to this Agreement without regard to the general deductions limitation of Section 848(c)(1848 (c)(1). 4. Both parties The Company and the Reinsurer agree to exchange information pertaining to the amount of the net consideration under this Agreement each year to ensure consistency or is as otherwise required by the Internal Revenue Service. 5. The Reinsured will Company shall submit a schedule to the Reinsurer by May June 1 of each year of its calculation of the net consideration for the preceding calendar year. This schedule of calculations will shall be accompanied by a statement signed by an officer of the Reinsured Company stating that the Reinsured will Company shall 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 Reinsured Company in writing within thirty (30) days of the Reinsurer's receipt of the ReinsuredCompany's calculation. If the Reinsurer does not so notify the ReinsuredCompany, the Reinsurer will shall report the net consideration as determined by the Reinsured Company in the Reinsurer's tax return for the previous calendar year. 7. If the Reinsurer contests the Reinsured' s Company's calculation 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) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Reinsurer and the Reinsurer Company reach agreement on an amount of net consideration, each party Party shall report such amount in their respective tax returns for the previous calendar year.

DAC TAX. SECTION 1.848-2(G(8) ELECTION 1. The term "party" will refer Parties to either this Agreement agree to the Reinsured or the Reinsurer as appropriate. 2. The terms used in this Article are defined by reference following provisions pursuant to Regulation Section 1.848-2 in effect 2(g)(8) of the Income Tax Regulations effective December 29, 1992., under Section 848 of the Internal Revenue Code of 1986, as amended: 3. a. The party 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 Section 848(c)(1). 4. b. Both parties Parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. The Reinsured c. If requested by the Reinsurer, the Company will submit a schedule to the Reinsurer by May 1 of each year of with 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 Reinsured stating that the Reinsured 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 Reinsured Company in writing within thirty (30) calendar days of the Reinsurer's ’s receipt of the Reinsured's Company’s calculation. If the Reinsurer does not so notify the ReinsuredCompany within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Company in the Reinsurer's ’s tax return for the previous calendar year. 7. d. If the Reinsurer contests the Reinsured' s Company’s calculation of the net consideration, the parties Parties will act in good faith to reach an agreement as to the correct amount within thirty (30) calendar days of the date the Reinsurer submits its alternative calculation. If the Reinsured Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall Party will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. e. Both the Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended.

DAC TAX. SECTION The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(G(82(g)(8) ELECTIONof the Income Tax Regulations issued under Section 848 of the Internal Revenue Code of 1986, as amended (the “Code”): 1. The term "party" will refer to either the Reinsured or the Reinsurer as appropriate. 2. A. The terms “Net Positive Consideration,” “Specified Policy Acquisition Expenses” and “General Deductions Limitation” used in this Article are defined by reference to Regulation Section 1.848-2 in effect December 1992and Code Section 848. 3. B. 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). 4. C. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency year, or is as otherwise required by the Internal Revenue Service. 5, to ensure consistency. The Reinsured method and timing of the exchange of such information shall be as follows: 1. The Company will submit a schedule to the Reinsurer by May 1 1st of each year of with its calculation of the net consideration Net Positive Consideration for the preceding calendar year. This schedule of calculations will be accompanied by a statement signed by an officer of the Reinsured Company stating that the Reinsured Company will report such net consideration Net Positive Consideration in its income tax return for the preceding calendar year. The Reinsurer may protest such calculation by providing an alternative calculation to the Company in writing within thirty (30) days of the Reinsurer’s receipt of the Company’s calculation. If the Reinsurer does not notify the Company within the required timeframe, the Reinsurer will report the Net Positive Consideration as determined by the Company in the Reinsurer’s income tax return for the preceding calendar year. 6. The Reinsurer may contest such calculation by providing an alternative calculation to the Reinsured in writing within thirty days of the Reinsurer's receipt of the Reinsured's calculation. If the Reinsurer does not so notify the Reinsured, the Reinsurer will report the net consideration as determined by the Reinsured in the Reinsurer's tax return for the previous calendar year. 72. If the Reinsurer contests the Reinsured' s Company’s calculation of the net considerationNet Positive Consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured parties reach an agreement on the amount of Net Positive Consideration, 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 Positive Consideration, then the dispute shall be resolved pursuant to ARTICLE XIII of this Agreement. D. Both the Company and the Reinsurer reach agreement on an amount represent and warrant that they are subject to United States taxation under either Subchapter L of net consideration, each party shall report such amount in their respective tax returns for Chapter 1 of the previous calendar yearCode or Subpart F of Part III of Subchapter N of Chapter 1 of the Code.

DAC TAX. SECTION 1.848-2(G(8The Company and the Reinsurer hereby agree to the following pursuant to Section 1.8482(g)(8) ELECTIONof the Income Tax Regulations issued December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended. This election shall be effective for all taxable years for which this Agreement remains in effect. 1. The term "party" will refer to either the Reinsured Company or the Reinsurer Reinsurer, as appropriate. 2. The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect as of December 29, 1992. 3. The party with the net positive consideration for this Agreement for each taxable year will capitalize specified policy acquisition expenses expense with respect to this Agreement without regard to the general deductions limitation of Section 848(c)(1848 (c)(1). 4. Both parties The Company and the Reinsurer agree to exchange information pertaining to the amount of the net consideration under this Agreement each year to ensure consistency or is as otherwise required by the Internal Revenue Service. 5. The Reinsured Reinsurer will submit a schedule to the Reinsurer Company by May June 1 of each year of its calculation of the net consideration for the preceding calendar year. This schedule of calculations will be accompanied by a statement state- ment signed by an officer of the Reinsured Reinsurer stating that the Reinsured Reinsurer will report such net consideration in its tax return for the preceding calendar year. 6. The Reinsurer Company may contest such calculation by providing an alternative calculation to the Reinsured Reinsurer in writing within thirty 30 days of the ReinsurerCompany's receipt of the ReinsuredReinsurer's calculation. If the Reinsurer Company does not so notify the ReinsuredReinsurer, the Reinsurer Company will report the net consideration as determined by the Reinsured Reinsurer in the ReinsurerCompany's tax return for the previous calendar year. 7. If the Reinsurer Company contests the Reinsured' s Reinsurer's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer Company submits its alternative calculation. If the Reinsured Company and the Reinsurer reach agreement on an amount of net consideration, each party shall report such amount in their respective tax returns for the previous calendar year.. GENERAL & COLOGNE LIFE RE OF AMERICA

DAC TAX. SECTION The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(G(82(g)(8) ELECTIONof the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. a. The term "“party" will refer ” refers to either the Reinsured Company or the Reinsurer Reinsurer, as appropriate. 2. b. The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992. 3. c. 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 with regard to the general deductions limitation of Section 848(c)(1). 4. d. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. e. The Reinsured Company will submit a schedule of calculations to the Reinsurer by May 1 of each year of with 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 Reinsured stating that the Reinsured 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 Reinsured Company in writing within thirty (30) days of the Reinsurer's ’s receipt of the Reinsured's Company’s calculation. If the Reinsurer does not so notify the ReinsuredCompany within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Company in the Reinsurer's ’s tax return for the previous calendar year. 7. f. If the Reinsurer contests the Reinsured' s Company’s calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. g. Both the Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended.

DAC TAX. SECTION 14.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(G(82(g)(8) ELECTIONof the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. (a) The term "`party" will refer ' refers to either the Reinsured Ceding Company or the Reinsurer Reinsurer, as appropriate. 2. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992. 3. (c) 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 Section 848(c)(1). 4. (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. (e) The Reinsured Ceding Company will submit a schedule to the Reinsurer by May April 1 of each year of with 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 Reinsured Ceding Company stating that the Reinsured Ceding 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 Reinsured Ceding Company in writing within thirty (30) days of the Reinsurer's receipt of the ReinsuredCeding Company's calculation. If the Reinsurer does not so notify the ReinsuredCeding Company within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Ceding Company in the Reinsurer's tax return for the previous calendar year. 7. (f) If the Reinsurer contests the Reinsured' s Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Ceding Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended. IDSL Succession Select Treaty

DAC TAX. SECTION 14.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(G(82(g)(8) ELECTIONof the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. (a) The term "`party" will refer ' refers to either the Reinsured Ceding Company or the Reinsurer Reinsurer, as appropriate. 2. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992. 3. (c) 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 Section 848(c)(1). 4. (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. (e) The Reinsured Ceding Company will submit a schedule to the Reinsurer by May April 1 of each year of with 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 Reinsured Ceding Company stating that the Reinsured Ceding 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 Reinsured Ceding Company in writing within thirty (30) days of the Reinsurer's receipt of the ReinsuredCeding Company's calculation. If the Reinsurer does not so notify advise the ReinsuredCeding Company within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Ceding Company in the Reinsurer's tax return for the previous calendar year. 7. (f) If the Reinsurer contests the Reinsured' s Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Ceding Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended. IDSL VUL4/LP Select Treaty 23

DAC TAX. SECTION 1.848-2(G(814.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848- 2(g)(8) ELECTIONof the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. (a) The term "`party" will refer ' refers to either the Reinsured Ceding Company or the Reinsurer Reinsurer, as appropriate. 2. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992. 3. (c) 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 Section 848(c)(1). 4. (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. (e) The Reinsured Ceding Company will submit a schedule to the Reinsurer by May April 1 of each year of with 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 Reinsured Ceding Company stating that the Reinsured Ceding 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 Reinsured Ceding Company in writing within thirty (30) days of the Reinsurer's receipt of the ReinsuredCeding Company's calculation. If the Reinsurer does not so notify advise the ReinsuredCeding Company within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Ceding Company in the Reinsurer's tax return for the previous calendar year. 7. (f) If the Reinsurer contests the Reinsured' s Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Ceding Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended.

DAC TAX. SECTION 1.848A. Each of the Company and the Reinsurer agrees that, for each taxable year during the Term and the five-2(G(8) ELECTION 1year period immediately following the Term, it will comply with the following provisions. The As used below, the term "“party" will refer ” refers to either the Reinsured Company or the Reinsurer Reinsurer, as appropriate. 2. The terms used in this Article are defined by reference to Regulation Section ) 1.848-2 of the Income Tax Regulations issued in effect December 19921992 under Section 848 of the Internal Revenue Code of 1986, as amended (the “Code”). 3. B. The party with the net positive consideration for this Agreement Treaty for each taxable year will capitalize specified policy acquisition expenses with respect to this Agreement Treaty without regard to the general deductions limitation of Section 848(c)(1)848(c)(l) of the Code. 4. Both C. The parties agree to shall exchange information pertaining to regarding the amount of net consideration paid under this Agreement Treaty in each year to ensure consistency or is consistency. The parties also agree to exchange information which may otherwise be required by the Internal Revenue Service. 5. D. The Reinsured Company will submit a schedule to the Reinsurer by May June 1 of each year of its calculation of the net consideration for the preceding calendar year. This Such schedule of calculations will be accompanied by a statement signed by an officer of the Reinsured Company stating that the Reinsured 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 Reinsured Company in writing within thirty 30 days of the Reinsurer's ’s receipt of the Reinsured's Company’s calculation. If the Reinsurer does not so notify the ReinsuredCompany, the Reinsurer will report the net consideration as determined by the Reinsured Company in the Reinsurer's ’s tax return for the previous calendar year. 7. If the Reinsurer contests the Reinsured' s Company’s calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) 30 days of the date the Reinsurer submits its alternative calculation. If the Reinsured Company and the Reinsurer reach agreement on an amount of net consideration, each party shall report such amount in their respective tax returns for the previous calendar year. If the parties still fail to reach agreement, the determination of net consideration shall be submitted to arbitration.

DAC TAX. SECTION The Company and the Reinsurer hereby agree to the following pursuant to Section 1.848-2(G(82(g)(8) ELECTIONof the Income Tax Regulations issued December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended. This election shall be effective for all taxable years for which this Agreement remains in effect. 1. A. The term "party" will refer to either the Reinsured Company or the Reinsurer Reinsurer, as appropriate. 2. B. The terms used in this Article are defined by reference to Regulation Section 1.848-2 1.848­2 in effect as of December 29, 1992. 3. C. The party with the net positive consideration for this Agreement for each taxable year will capitalize specified policy acquisition expenses expense with respect to this Agreement without regard to the general deductions limitation of Section 848(c)(1848 (c)(1). 4. Both parties D. The Company and the Reinsurer agree to exchange information pertaining to the amount of the net consideration under this Agreement each year to ensure consistency or is as otherwise required by the Internal Revenue Service. 5. E. The Reinsured Company will submit a schedule to the Reinsurer by May June 1 of each year 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 Reinsured Company stating that the Reinsured Company will report such net consideration in its tax return for the preceding calendar year. 6. F. The Reinsurer may contest such calculation by providing an alternative calculation to the Reinsured Company in writing within thirty (30) days of the Reinsurer's receipt of the ReinsuredCompany's calculation. If the Reinsurer does not so notify the ReinsuredCompany, the Reinsurer will report the net consideration as determined by the Reinsured Company in the Reinsurer's tax return for the previous calendar year. 7. G. If the Reinsurer contests the Reinsured' s Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Reinsurer and the Reinsurer Company reach agreement on an amount of net consideration, each party shall report such amount in their respective tax returns for the previous calendar year.

DAC TAX. SECTION 1.848-2(G(814.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848- 2(g) ELECTION(8) of the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. (a) The term "`party" will refer ' refers to either the Reinsured Ceding Company or the Reinsurer Reinsurer, as appropriate. 2. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992. 3. (c) 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 Section 848(c)(1). 4. (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. (e) The Reinsured Ceding Company will submit a schedule to the Reinsurer by May 1 April I of each year of with 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 Reinsured Ceding Company stating that the Reinsured Ceding 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 Reinsured Ceding Company in writing within thirty (30) days of the Reinsurer's receipt of the ReinsuredCeding Company's calculation. If the Reinsurer does not so notify advise the ReinsuredCeding Company within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Ceding Company in the Reinsurer's tax return for the previous calendar year. 7. (f) If the Reinsurer contests the Reinsured' s Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Ceding Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended. IDSL VUL4 / LP Select Treaty 24

DAC TAX. SECTION Treasury Regulation Section 1.848-2(G(82(g)(8) ELECTIONElection The CEDING COMPANY and the REINSURER hereby agree to the following pursuant to Section 1.848-2(g)(8) of the Income Tax Regulations issued December 29, 1992, under Section 848 of the Internal Revenue Code 1986, as amended. This election shall be effective for the year this Agreement becomes effective and all subsequent taxable years for which this Agreement remains in effect. 1. A. The term "party" will refer to either the Reinsured CEDING COMPANY or the Reinsurer REINSURER as appropriate. 2. B. The terms used in this Article are defined by reference to Regulation Treasury Regulations Section 1.848-2 in effect as of December 29, 1992. 3. C. 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 deduction limitation of IRC Section 848(c)(1). 4. D. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency or is consistency. The parties also agree to exchange information, which may be otherwise required by the Internal Revenue ServiceIRS. 5. E. The Reinsured CEDING COMPANY will submit to the REINSURER by April 1st of each year, a schedule to the Reinsurer by May 1 of each year 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 Reinsured CEDING COMPANY stating that the Reinsured CEDING COMPANY will report such net consideration in its tax return for the preceding calendar year. 6. F. The Reinsurer REINSURER may contest such calculation by providing an alternative alternate calculation to the Reinsured CEDING COMPANY in writing within thirty (30) days of the ReinsurerREINSURER's receipt of the ReinsuredCEDING COMPANY's calculation. If the Reinsurer REINSURER does not so notify the ReinsuredCEDING COMPANY, the Reinsurer REINSURER will report the net consideration as determined by the Reinsured CEDING COMPANY in the ReinsurerREINSURER's tax return for the previous calendar year. 7. G. If the Reinsurer REINSURER contests the Reinsured' s CEDING COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer REINSURER submits its alternative alternate calculation. If the Reinsured REINSURER and the Reinsurer CEDING COMPANY reach agreement on an amount of net consideration, each party shall report such amount in their respective tax returns for the previous calendar year.. -------------------------------------------------------------------------------- GE Life and Annuity Assurance Co., Agreement No. Page 25 Effective February 15, 2002

DAC TAX. SECTION Treasury Regulation Section 1.848-2(G(82(g)(8) ELECTIONElection The CEDING COMPANY and the REINSURER hereby agree to the following pursuant to Section 1.848-2(g)(8) of the Income Tax Regulations issued December 29, 1992, under Section 848 of the Internal Revenue Code 1986, as amended. This election shall be effective for the year this Agreement becomes effective and all subsequent taxable years for which this Agreement remains in effect. 1. A. The term "party" will refer to either the Reinsured CEDING COMPANY or the Reinsurer REINSURER as appropriate. 2. B. The terms used in this Article are defined by reference to Regulation Treasury Regulations Section 1.848-2 in effect as of December 29, 1992. 3. C. 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 deduction limitation of IRC Section 848(c)(1). 4. D. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency or is consistency. The parties also agree to exchange information, which may be otherwise required by the Internal Revenue ServiceIRS. 5. E. The Reinsured CEDING COMPANY will submit to the REINSURER by April 1st of each year, a schedule to the Reinsurer by May 1 of each year 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 Reinsured CEDING COMPANY stating that the Reinsured CEDING COMPANY will report such net consideration in its tax return for the preceding calendar year. 6. F. The Reinsurer REINSURER may contest such calculation by providing an alternative alternate calculation to the Reinsured CEDING COMPANY in writing within thirty (30) days of the ReinsurerREINSURER's receipt of the ReinsuredCEDING COMPANY's calculation. If the Reinsurer REINSURER does not so notify the ReinsuredCEDING COMPANY, the Reinsurer REINSURER will report the net consideration as determined by the Reinsured CEDING COMPANY in the ReinsurerREINSURER's tax return for the previous calendar year. 7. G. If the Reinsurer REINSURER contests the Reinsured' s CEDING COMPANY's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer REINSURER submits its alternative alternate calculation. If the Reinsured REINSURER and the Reinsurer CEDING COMPANY reach agreement on an amount of net consideration, each party shall report such amount in their respective tax returns for the previous calendar year.. -------------------------------------------------------------------------------- GE Capital of New York, Agreement No.2001-51 Page 21 Effective July 1, 2001

DAC TAX. SECTION 1.848-2(G(8The Parties to this Agreement agree to the following provisions pursuant to Section 1.848­2(g)(8) ELECTIONof the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. The term "partyParty" will shall refer to either the Reinsured Company or the Reinsurer as appropriate. 2. The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect as of December 29, 1992. 3. The party Party with the net positive consideration for this Agreement for each taxable year will shall capitalize specified policy acquisition expenses expense with respect to this Agreement without regard to the general deductions limitation of Section 848(c)(1). 4. Both parties The Company and the Reinsurer agree to exchange information pertaining to the amount of the net consideration under this Agreement each year to ensure consistency or is as otherwise required by the Internal Revenue Service. 5. The Reinsured will Company shall submit a schedule to the Reinsurer by May June 1 of each year of its calculation of the net consideration for the preceding calendar year. This schedule of calculations will shall be accompanied by a statement signed by an officer of the Reinsured Company stating that the Reinsured will Company shall 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 Reinsured Company in writing within thirty (30) days of the Reinsurer's receipt of the ReinsuredCompany's calculation. If the Reinsurer does not so notify the ReinsuredCompany, the Reinsurer will shall report the net consideration as determined by the Reinsured Company in the Reinsurer's tax return for the previous calendar year. 7. If the Reinsurer contests the Reinsured' s Company's calculation of the net consideration, the parties will shall act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Company and the Reinsurer reach agreement on an amount of net consideration, each party shall report such amount in their respective tax returns for the previous calendar year. 8. Both the Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended.

DAC TAX. SECTION 1.848-2(G(814.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848- 2(g)(8) ELECTIONof the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. (a) The term "'party" will refer ' refers to either the Reinsured Ceding Company or the Reinsurer Reinsurer, as appropriate. 2. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992. 3. (c) 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 Section 848(c)(1). 4. (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. (e) The Reinsured Ceding Company will submit a schedule to the Reinsurer by May April 1 of each year of with 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 Reinsured Ceding Company stating that the Reinsured Ceding 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 Reinsured Ceding Company in writing within thirty (30) days of the Reinsurer's receipt of the ReinsuredCeding Company's calculation. If the Reinsurer does not so notify advise the ReinsuredCeding Company within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Ceding Company in the Reinsurer's tax return for the previous calendar year. 7. (f) If the Reinsurer contests the Reinsured' s Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Ceding Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended. IDSL-NY VUL4/LP Select Treaty 24

DAC TAX. SECTION 14.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(G(82(g)(8) ELECTIONof the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. (a) The term "`party" will refer ' refers to either the Reinsured Ceding Company or the Reinsurer Reinsurer, as appropriate. 2. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992. 3. (c) 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 Section 848(c)(1). 4. (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. (e) The Reinsured Ceding Company will submit a schedule to the Reinsurer by May April 1 of each year of with 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 Reinsured Ceding Company stating that the Reinsured Ceding 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 Reinsured Ceding Company in writing within thirty (30) days of the Reinsurer's receipt of the ReinsuredCeding Company's calculation. If the Reinsurer does not so notify the ReinsuredCeding Company within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Ceding Company in the Reinsurer's tax return for the previous calendar year. 7. (f) If the Reinsurer contests the Reinsured' s Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Ceding Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall will report such the agreed upon amount in their respective its tax returns return for the previous calendar year.

DAC TAX. SECTION 14.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(G(82(g)(8) ELECTIONof the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. (a) The term "`party" will refer ' refers to either the Reinsured Ceding Company or the Reinsurer Reinsurer, as appropriate. 2. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992. 3. (c) 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 Section 848(c)(1). 4. (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. (e) The Reinsured Ceding Company will submit a schedule to the Reinsurer by May April 1 of each year of with 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 Reinsured Ceding Company stating that the Reinsured Ceding 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 Reinsured Ceding Company in writing within thirty (30) days of the Reinsurer's receipt of the ReinsuredCeding Company's calculation. If the Reinsurer does not so notify advise the ReinsuredCeding Company within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Ceding Company in the Reinsurer's tax return for the previous calendar year. 7. (f) If the Reinsurer contests the Reinsured' s Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Ceding Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended. IDSL-NY VUL4/LP Select Treaty 24

DAC TAX. SECTION 1) The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(G(82(g)(8) ELECTIONof the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: 1. a. The term "‘party" will refer ’ refers to either the Reinsured Company or the Reinsurer Reinsurer, as appropriate. 2. b. The terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992. 3. c. 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 with regard to the general deductions limitation of Section 848(c)(1). 4. d. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service. 5. e. The Reinsured Company will submit a schedule to the Reinsurer by May 1 of each year of with 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 Reinsured Company stating that the Reinsured 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 Reinsured Company in writing within thirty (30) days of the Reinsurer's ’s receipt of the Reinsured's Company’s calculation. If the Reinsurer does not so notify the ReinsuredCompany within the required timeframe, the Reinsurer will report the net consideration as determined by the Reinsured Company in the Reinsurer's ’s tax return for the previous calendar year. 7. f. If the Reinsurer contests the Reinsured' s Company’s calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Reinsured Company and the Reinsurer reach an agreement on an amount of net consideration, each party shall will report such the agreed upon amount in their respective its tax returns return for the previous calendar year. g. Both the Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended.

DAC TAX. SECTION The Ceding Company and the Reinsurer hereby agree to the following, pursuant to Section 1.848-2(G(82(g)(8) ELECTIONof the Income Tax Regulation issued December 1992, under Section 848 of the Internal Revenue Code of 1986: 1. The a. the term "“party" will refer ” refers to either the Reinsured Ceding Company or the Reinsurer Reinsurer, as appropriate.; 2. The b. the terms used in this Article are defined by reference to Regulation Section 1.848-2 in effect 2, effective December 29, 1992.; 3. The c. 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 Section 848(c)(1).; 4. Both d. all parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency consistency, or is as otherwise required by the Internal Revenue Service.; 5. The Reinsured e. the Reinsurer will submit a schedule to the Reinsurer Ceding Company by May April 1 of each year 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 Reinsured stating that the Reinsured Reinsurer will report such net consideration in its tax return for the preceding calendar year.; 6. The Reinsurer f. the Ceding Company may contest such calculation by providing an alternative calculation to the Reinsured in writing within thirty days of the Reinsurer's receipt of the Reinsured's calculationReinsurer by May 1. If the Reinsurer Ceding Company does not so notify the ReinsuredReinsurer by May 1, the Reinsurer will report the net consideration as determined by the Reinsured considerations reported in the Reinsurer's ’s tax return for returns will be the previous calendar year.value as defined in Item (e) above; 7. If g. if the Reinsurer contests the Reinsured' s calculation of the net considerationCeding Company submits its alternative calculation, the parties will act in good faith to reach an agreement as to on the correct amount within thirty (30) calendar days of the date the Reinsurer Ceding Company submits its alternative calculation. If the Reinsured Ceding Company and the Reinsurer reach agreement on an amount of the net consideration, each party shall report such amount in their respective tax returns for the previous calendar year; and h. the Ceding Company and the Reinsurer represent and warrant that they are subject to United States taxation under either Subchapter L or Subpart F of Part III of Subchapter N of the Internal Revenue Code of 1986, as amended.