Common use of DAC TAX Clause in Contracts

DAC TAX. 14.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(g)(8) of the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: (a) The term `party' refers to either the Ceding Company or the Reinsurer, as appropriate. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2, effective December 29, 1992. (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). (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency, or as otherwise required by the Internal Revenue Service. (e) The Ceding Company will submit a schedule to the Reinsurer by April 1 of each year 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 Ceding Company stating that the Ceding Company will report such net consideration in its 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) days of the Reinsurer's receipt of the Ceding Company's calculation. If the Reinsurer does not so notify the Ceding Company within the required timeframe, the Reinsurer will report the net consideration as determined by the Ceding Company in the Reinsurer's tax return for the previous calendar year. (f) If the Reinsurer contests the Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer submits its alternative calculation. If the Ceding Company and the Reinsurer reach an agreement on an amount of net consideration, each party will report the agreed upon amount in its tax 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. 14.1 A. The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(g)(8) of the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: (a) The term `party' refers to either the Ceding Company or the Reinsurer, as appropriate. (b) 1. The terms used in this Article are defined by reference to Regulation Section 1.848-2, effective December 29, 1992. (c) 2. 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). (d) 3. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency, or as otherwise required by the Internal Revenue Service. (e) 4. The Ceding Company will submit a schedule to the Reinsurer Generali USA by April May 1 of each year 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 Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year. The Reinsurer Generali USA may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) days of the ReinsurerGenerali USA's receipt of the Ceding Company's calculation. If the Reinsurer Generali USA does not so notify the Ceding Company within the required timeframe, the Reinsurer Generali USA will report the net consideration as determined by the Ceding Company in the ReinsurerGenerali USA's tax return for the previous calendar year. (f) 5. If the Reinsurer Generali USA contests the Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer Generali USA submits its alternative calculation. If the Ceding Company and the Reinsurer Generali USA reach an agreement on an amount of net consideration, each party will report the agreed upon amount in its tax return for the previous calendar year. (g) 6. Both the Ceding Company and the Reinsurer Generali USA 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. 7. IDSL-NY Succession Select TreatyThis election is effective beginning with the taxable year in which the Coverage Effective Date occurs. To the extent required by law, both parties will attach a schedule (similar to that shown in Exhibit A to this Agreement) to their respective federal income tax returns filed for the first taxable year ending after the date this election becomes effective, which identifies the reinsurance agreement for which this election has been made.

DAC TAX. 14.1 13.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(g)(8) of the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: (a) The term `‘party' ’ refers to either the Ceding Company or the ReinsurerMARC, as appropriate. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2, effective December 29, 1992. (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). (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency, or as otherwise required by the Internal Revenue Service. (e) The Ceding Company will submit a schedule to the Reinsurer MARC by April 1 of each year 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 Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year. The Reinsurer MARC may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) days of the Reinsurer's MARC’s receipt of the Ceding Company's ’s calculation. If the Reinsurer MARC does not so notify the Ceding Company within the required timeframe, the Reinsurer MARC will report the net consideration as determined by the Ceding Company in the Reinsurer's MARC’s tax return for the previous calendar year. (f) If the Reinsurer MARC contests the Ceding Company's ’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 MARC submits its alternative calculation. If the Ceding Company and the Reinsurer MARC reach an agreement on an amount of net consideration, each party will report the agreed upon amount in its tax return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer MARC 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. 14.1 The Section 1. 848-2(g)(8) Election 17.1 If applicable, both parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(g)(8) } of the Income Tax Regulations effective issued December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended:. This election shall be effective for all subsequent taxable years for which this Agreement remains in effect. (a) 17.2 The term `party' refers “party11 shall refer to either the Ceding Company or the Reinsurer, Reinsurer as appropriate. (b) 17.3 The terms used in this Article are defined by reference to Regulation Section 1.848-2, effective 2 of the Income Tax Regulations in effect December 29, 1992. (c) 17.4 The 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 Section 848(c)(1)) of the Internal Revenue Code of 1986. (d) 17.5 Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency, consistency or as otherwise required by the Internal Revenue Service.. Effective 10/01/2012 CONFIDENTIAL Table of Contents (e) 17.6 The Ceding Company will shall submit a schedule to the Reinsurer by April 1 of each year with 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 one of the Ceding Company Company’s officers stating that the Ceding Company will shall report such net consideration in its tax return for the preceding calendar year. . 17.7 The Reinsurer may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) days of the Reinsurer's ’s receipt of the Ceding Company's ’s calculation. If the Reinsurer does not so notify the Ceding Company within the required timeframeCompany, the Reinsurer will shall report the net consideration as determined by the Ceding Company in the Reinsurer's ’s tax return for the previous calendar year. (f) 17.8 If the Reinsurer contests the Ceding Company's ’s calculation of the net consideration, the both 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 Ceding Company and the Reinsurer both parties reach an agreement on an amount of net consideration, each party will shall report the agreed upon such amount in its respective tax return returns 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. 14.1 13.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(g)(8) of the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: (a) The term `‘party' ’ refers to either the Ceding Company or the ReinsurerMARC, as appropriate. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2, effective December 29, 1992. (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). (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency, or as otherwise required by the Internal Revenue Service. (e) The Ceding Company MARC will submit a schedule to the Reinsurer Ceding Company by April 1 of each year 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 Ceding Company MARC stating that the Ceding Company MARC will report such net consideration in its tax return for the preceding calendar year. The Reinsurer Ceding Company may contest such calculation by providing an alternative calculation to the Ceding Company MARC in writing within thirty (30) days of the Reinsurer's Ceding Company’s receipt of the Ceding Company's MARC’s calculation. If the Reinsurer Ceding Company does not so notify the Ceding Company MARC within the required timeframe, the Reinsurer Ceding Company will report the net consideration as determined by MARC in the Ceding Company in the Reinsurer's Company’s tax return for the previous calendar year. (f) If the Reinsurer Ceding Company contests the Ceding Company's MARC’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 Ceding Company submits its alternative calculation. If the Ceding Company and the Reinsurer MARC reach an agreement on an amount of net consideration, each party will report the agreed upon amount in its tax return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer MARC 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. 14.1 13.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(g)(8) of the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: (a) The term `‘party' ’ refers to either the Ceding Company or the ReinsurerIHLIC, as appropriate. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2, effective December 29, 1992. (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). (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency, or as otherwise required by the Internal Revenue Service. (e) The Ceding Company will submit a schedule to the Reinsurer IHLIC by April 1 of each year 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 Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year. The Reinsurer IHLIC may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) days of the Reinsurer's IHLIC’s receipt of the Ceding Company's ’s calculation. If the Reinsurer IHLIC does not so notify the Ceding Company within the required timeframe, the Reinsurer IHLIC will report the net consideration as determined by the Ceding Company in the Reinsurer's IHLIC’s tax return for the previous calendar year. (f) If the Reinsurer IHLIC contests the Ceding Company's ’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 IHLIC submits its alternative calculation. If the Ceding Company and the Reinsurer IHLIC reach an agreement on an amount of net consideration, each party will report the agreed upon amount in its tax return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer IHLIC 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. 14.1 The parties Parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(g)(8) of the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: (a) The term `party' refers to either the Ceding Company or the Reinsurer, as appropriate. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2, effective December 29, 1992. (cb) 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). (dc) Both parties Parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency, or as otherwise required by the Internal Revenue Service. (ed) The Ceding Company will submit a schedule to the Reinsurer MARC by [April 1 1] of each year 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 Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year. The Reinsurer MARC may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) days of the Reinsurer's MARC’s receipt of the Ceding Company's ’s calculation. If the Reinsurer MARC does not so notify the Ceding Company within the required timeframe, the Reinsurer MARC will report the net consideration as determined by the Ceding Company in the Reinsurer's MARC’s tax return for the previous calendar year. (fe) If the Reinsurer MARC contests the Ceding Company's ’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 MARC submits its alternative calculation. If the Ceding Company and the Reinsurer MARC reach an agreement on an amount of net consideration, each party Party will report the agreed upon amount in its tax return for the previous calendar year. (gf) Both the Ceding Company and the Reinsurer MARC 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. 14.1 Treasury Regulation Section 1.848-2(g)(8) Election The parties to this Agreement CEDING COMPANY and the REINSURER hereby agree to the following provisions pursuant to the Section 1.848-2(g)(8) of the Income Tax Regulations effective issued December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended:. This election shall be effective for 1993 and all subsequent taxable years for which this Agreement remains in effect. (a) A. The term `"party' refers " will refer to either the Ceding Company CEDING COMPANY or the Reinsurer, REINSURER as appropriate. (b) B. The terms used in this Article are defined by reference to Regulation Treasury Regulations Section 1.848-2, effective 2 in effect as of December 29, 199229,1992. (c) 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). (d) D. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency. The parties also agree to exchange information, or as which may be otherwise required by the Internal Revenue ServiceIRS. (e) E. The Ceding Company CEDING COMPANY will submit to the REINSURER by April 1st of each year, a schedule to the Reinsurer by April 1 of each year 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 Ceding Company CEDING COMPANY stating that the Ceding Company CEDING COMPANY will report such net consideration in its tax return for the preceding calendar year. . F. The Reinsurer REINSURER may contest such calculation by providing an alternative alternate calculation to the Ceding Company CEDING COMPANY in writing within thirty (30) days of the Reinsurer's REINSURER'S receipt of the Ceding Company's CEDING COMPANY'S calculation. If the Reinsurer REINSURER does not so notify the Ceding Company within the required timeframeCEDING COMPANY, the Reinsurer REINSURER will report the net consideration as determined by the Ceding Company CEDING COMPANY in the Reinsurer's REINSURER'S tax return for the previous calendar year. (f) G. If the Reinsurer REINSURER contests the Ceding Company'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 Ceding Company REINSURER and the Reinsurer CEDING COMPANY reach an agreement on an amount of net consideration, each party will shall report the agreed upon such amount in its their respective tax return returns 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. 14.1 A. The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(g)(8) of the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: (a) The term `party' refers to either the Ceding Company or the Reinsurer, as appropriate. (b) 1. The terms used in this Article are defined by reference to Regulation Section 1.848-2, effective December 29, 1992. (c) 2. 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). (d) 3. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency, or as otherwise required by the Internal Revenue Service. (e) 4. The Ceding Company will submit a schedule to the Reinsurer Generali USA by April May 1 of each year 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 Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year. The Reinsurer Generali USA may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) days of the ReinsurerGenerali USA's receipt of the Ceding Company's calculation. If the Reinsurer Generali USA does not so notify the Ceding Company within the required timeframe, the Reinsurer Generali USA will report the net consideration as determined by the Ceding Company in the ReinsurerGenerali USA's tax return for the previous calendar year. (f) 5. If the Reinsurer Generali USA contests the Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer Generali USA submits its alternative calculation. If the Ceding Company and the Reinsurer Generali USA reach an agreement on an amount of net consideration, each party will report the agreed upon amount in its tax return for the previous calendar year. (g) 6. Both the Ceding Company and the Reinsurer Generali USA 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. 14.1 13.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(g)(8) of the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: (a) The term `party' refers to either the Ceding Company or the ReinsurerMARC, as appropriate. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2, effective December 29, 1992. (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). (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency, or as otherwise required by the Internal Revenue Service. (e) The Ceding Company will submit a schedule to the Reinsurer MARC by April 1 of each year 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 Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year. The Reinsurer MARC may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) days of the ReinsurerMARC's receipt of the Ceding Company's calculation. If the Reinsurer MARC does not so notify the Ceding Company within the required timeframe, the Reinsurer MARC will report the net consideration as determined by the Ceding Company in the ReinsurerMARC's tax return for the previous calendar year. (f) If the Reinsurer MARC contests the Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer MARC submits its alternative calculation. If the Ceding Company and the Reinsurer MARC reach an agreement on an amount of net consideration, each party will report the agreed upon amount in its tax return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer MARC 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. 14.1 The parties to this Agreement Ceding Company and Allianz Life hereby agree to the following provisions pursuant to Section 1.848-2(g)(8) of the Income Tax Regulations effective Regulation issued December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended:. (a) 1. The term `"party' refers " will refer to either the Ceding Company or the Reinsurer, Allianz Life as appropriate. (b) 2. The terms used in this Article are defined by reference to Regulation Section 1.848-2, effective 2 in effect December 29, 1992. (c) 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). (d) 4. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency, consistency or as otherwise required by the Internal Revenue Service. (e) The Ceding Company 5. Allianz Life will submit a schedule to the Reinsurer Ceding Company by April 1 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 Ceding Company stating that the Ceding Company Allianz Life will report such net consideration in its tax return for the preceding calendar year. 6. The Reinsurer Ceding Company may contest such calculation by providing an alternative calculation to Allianz Life by May 1 of the year following the end of the taxable year. If the Ceding Company does not notify Allianz Life by May I, the net considerations reported in writing within thirty (30) days of the Reinsurer's receipt of respective tax returns will be the Ceding Company's calculationvalue as defined in Item 5 above. 7. If the Reinsurer does not so notify the Ceding Company within the required timeframe, the Reinsurer will report the net consideration as determined by the Ceding Company in the Reinsurer's tax return for the previous calendar year. (f) If the Reinsurer contests the Ceding CompanyAllianz Life's calculation of the net consideration, the parties will act in good faith to reach an agreement as to on the correct amount within thirty (30) days of the date the Reinsurer Ceding Company submits its alternative calculation. If the Ceding Company and the Reinsurer Allianz Life reach an agreement on an amount of the net consideration, each party will shall report the agreed upon such amount in its their respective tax return returns for the previous calendar year. . SCHEDULE A RETENTION LIMITS SECURITY EQUITY LIFE RETENTION All Ages $125,000 ALLIANZ LIFE INSURANCE COMPANY OF NORTH AMERICA SCHEDULE B ALLIANZ (gLOGO) Both the 00 XXXXXXXX XXXXXX XXXXX ___ NEW BUSINESS CESSION XXXXXXXXXXX, XX 00000-0000 ___ AMENDED CESSION ___ COINSURANCE __ YRT Automatic Faculative Fac-Oblig. REINSURANCE APPLICATION Participating Non-Participating ___ ____ ____ U. S.__ CANADIAN ___ ___ _____ Ceding Company Agency Application No. Date Insured's Name Age Birthdate State of Birth State of Residence Social Security # Occupation Height Weight Medical Non-Medical Male Female ___ ___ ___ ___ INSURANCE INFORMATION LIFE RIDER DISABILITY ACC. DEATH PLAN Previous Insurance in force by us Substandard Rating Obtained by us Issuing new insurance for Substandard rating Obtained by us Required Reinsurance Has risk submitted to us previously formally or informally? __ No _ Yes: __War Clause ___ No __Yes: __Aviation Clause __No ___Yes We are reporting the following codes to M.I.B: This case has/has not been submitted elsewhere for reinsurance, 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 amendedwe have/have not been refused coverage on this risk. IDSL-NY Succession Select TreatyReason for declination: REMARKS: CESSION OF REINSURANCE COMPOSITE __ SMOKER __ NONSMOKER __ PREFERRED ___ LIFE RIDER WP/DISABILITY ACC- DEATH PLAN Current Issue Base Retained by us Reinsurance Rider Rating Policy Number Policy Date Reserve Basis Allianz Life Reinsurance Number

DAC TAX. 14.1 The parties to this Agreement Ceding Company and Allianz Life hereby agree to the following provisions pursuant to Section 1.848-2(g)(8) of the Income Tax Regulations effective Regulation issued December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended:. (a) 1. The term `“party' refers ” will refer to either the Ceding Company or the Reinsurer, Allianz Life as appropriate. (b) 2. The terms used in this Article are defined by reference to Regulation Section 1.848-2, effective 2 in effect December 29, 1992. (c) 3. The party with the net positive consideration for this Agreement agreement for each taxable year will capitalize specified policy acquisition expenses with respect to this Agreement agreement without regard to the general deductions limitation of Section 848(c)(1848 (c)(1). (d) 4. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement agreement each year to ensure consistency, consistency or as otherwise required by the Internal Revenue Service. (e) The Ceding Company 5. Allianz Life will submit a schedule to the Reinsurer Ceding Company by April 1 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 Ceding Company stating that the Ceding Company Allianz Life will report such net consideration in its tax return for the preceding calendar year. 6. The Reinsurer Ceding Company may contest such calculation by providing an alternative calculation to Allianz Life by May 1, of the year following the end of the taxable year. If the Ceding Company does not notify Allianz Life by May 1, the net considerations reported in writing within thirty (30) days of the Reinsurer's receipt of respective tax returns will be the Ceding Company's calculationvalue as defined in Item 5 above. 7. If the Reinsurer does not so notify the Ceding Company within the required timeframe, the Reinsurer will report the net consideration as determined by the Ceding Company in the Reinsurer's tax return for the previous calendar year. (f) If the Reinsurer contests the Ceding Company's Allianz Life’s calculation of the net consideration, the parties will act in good faith to reach an agreement as to on the correct amount within thirty (30) days of the date the Reinsurer Ceding Company submits its alternative calculation. If the Ceding Company and the Reinsurer Allianz Life reach an agreement on an amount of the net consideration, each party will shall report the agreed upon such amount in its their respective tax return returns for the previous calendar year. (g) Both the . 700 Xxxxxxxx Xxxxxx o NEW BUSINESS CESSION Ixxxxxxxxxxx, XX 00000-0000 o AMENDED CESSION natic o Facultative o Fac-Oblig. o U.S. o CANADIAN o o COINSURANCE o YRT REINSURANCE APPLICATION Ceding Company Agency Application No. Date Insured’s Name Age Birthdate State of Birth State of Residence Social Security # Occupation Height Weight Medical o Non-Medical o Male o Female o evious Insurance in force by us bstandard Rating etained by us suing new insurance for bstandard rating etained by us equired Reinsurance as risk submitted to us previously formally or informally? o No o Yes; War Clause o No o Yes; Aviation Clause o No o Yes a are reporting the following codes to M.I.B.: its case has/has not been submitted elsewhere for reinsurance, 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 amendedwe have/have not been refused coverage on this risk. IDSL-NY Succession Select TreatyReason for declination: trrent issue Base gained by us insurance Rider ding obey Number Policy Date Reserve Basis Allianz Life Reinsurance Number

DAC TAX. 14.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(g)(8) of the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: (a) The term `‘party' ’ refers to either the Ceding Company or the ReinsurerMARC, as appropriate. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2, effective December 29, 1992. (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). (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency, or as otherwise required by the Internal Revenue Service. (e) The Ceding Company will submit a schedule to the Reinsurer MARC by April 1 of each year 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 Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year. The Reinsurer MARC may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) days of the Reinsurer's MARC’s receipt of the Ceding Company's ’s calculation. If the Reinsurer MARC does not so notify the Ceding Company within the required timeframe, the Reinsurer MARC will report the net consideration as determined by the Ceding Company in the Reinsurer's MARC’s tax return for the previous calendar year. (f) If the Reinsurer MARC contests the Ceding Company's ’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 MARC submits its alternative calculation. If the Ceding Company and the Reinsurer MARC reach an agreement on an amount of net consideration, each party will report the agreed upon amount in its tax return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer MARC 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. 14.1 The parties to this Agreement ELECTION Ceding Company and Reinsurer hereby agree to make the following provisions election pursuant to IRS Regulation Section 1.848-2(g)(8) of the Income Tax Regulations effective December 291.848‑2(g)(8), 1992, under promulgated pursuant to Section 848 of the Internal Revenue Code of 1986, as amended: (a. This election shall be effective for 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) The term `party' refers to either the Ceding Company or the Reinsurer, as appropriateof such Regulation. (b) 1. The terms used in this Article are defined by reference to Regulation Section 1.848-2, effective December 29, 19921.848‑2 in effect on the date hereof. (c) 2. The party Party with the net positive consideration for this Reinsurance Agreement for each taxable year will capitalize specified policy acquisition expenses with respect to this Reinsurance Agreement without regard to the general deductions limitation of Section 848(c)(1). (d) 3. Both parties Parties agree to exchange information pertaining to the amount of net consideration under this Reinsurance Agreement each year to ensure consistency, consistency or as otherwise required by the Internal Revenue Service. (e) The 4. Ceding Company will submit a schedule to the Reinsurer by April 1 May 31 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 Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year. 5. 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 ’s receipt of the Ceding Company's ’s calculation. If the Reinsurer does not so notify the Ceding Company within the required timeframeCompany, the Reinsurer will report the net consideration as determined by the Ceding Company in the Reinsurer's ’s tax return for the previous calendar year. (f) 6. If the Reinsurer contests the Ceding Company's ’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 Ceding Company and the Reinsurer reach an agreement on an amount of net consideration, each party will Party shall report the agreed upon such amount in its their respective tax return returns for the previous calendar year. (g) Both . SCHEDULE 4.5 QUARTERLY REPORTS In addition to 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 reports set forth in Section 4.5 of the Internal Revenue Code of 1986Reinsurance Agreement, as amendedReinsurer shall provide the following Quarterly Reports to Ceding Company: 1. IDSL-NY Succession Select TreatyTrust statement and certification from the trustee(s) that investments are within the appropriate compliance levels; 2. Profit & loss in aggregate and by strategy, highlighting realized and unrealized gains/losses; 3. Sector allocation; 4. Holdings individually, by strategy; 5. Compliance with the Investment Guidelines; 6. Upgrade/downgrade listing; and 7. Quarterly valuation opinions and security documentation from outside vendor.

DAC TAX. 14.1 13.1 The parties to this Agreement agree to the following provisions pursuant to Section 1.848-2(g)(8) of the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: (a) The term `party' refers to either the Ceding Company or the ReinsurerMARC, as appropriate. (b) The terms used in this Article are defined by reference to Regulation Section 1.848-2, effective December 29, 1992. (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). (d) Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency, or as otherwise required by the Internal Revenue Service. (e) The Ceding Company will submit a schedule to the Reinsurer MARC by April 1 of each year 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 Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year. The Reinsurer MARC may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) days of the ReinsurerMARC's receipt of the Ceding Company's calculation. If the Reinsurer MARC does not so notify the Ceding Company within the required timeframe, the Reinsurer MARC will report the net consideration as determined by the Ceding Company in the ReinsurerMARC's tax return for the previous calendar year. (f) If the Reinsurer MARC contests the Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer MARC submits its alternative calculation. If the Ceding Company and the Reinsurer MARC reach an agreement on an amount of net consideration, each party will report the agreed upon amount in its tax return for the previous calendar year. (g) Both the Ceding Company and the Reinsurer MARC 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 Treaty17 -------------------------------------------------------------------------------- [GRAPHIC OMITTED] MARC MUNICH RE GROUP

DAC TAX. 14.1 A. The parties to this Agreement agree to the following provisions pursuant to Section 1.848-I.848- 2(g)(8) of the Income Tax Regulations effective December 29, 1992, under Section 848 of the Internal Revenue Code of 1986, as amended: (a) The term `party' refers to either the Ceding Company or the Reinsurer, as appropriate. (b) 1. The terms used in this Article are defined by reference to Regulation Section 1.848-2, effective December 29, 1992. (c) 2. 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)(1848(c)(I). (d) 3. Both parties agree to exchange information pertaining to the amount of net consideration under this Agreement each year to ensure consistency, or as otherwise required by the Internal Revenue Service. (e) 4. The Ceding Company will submit a schedule to the Reinsurer Generali USA by April May 1 of each year 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 Ceding Company stating that the Ceding Company will report such net consideration in its tax return for the preceding calendar year. The Reinsurer Generali USA may contest such calculation by providing an alternative calculation to the Ceding Company in writing within thirty (30) days of the ReinsurerGenerali USA 's receipt of the Ceding Company's calculation. If the Reinsurer Generali USA does not so notify the Ceding Company within the required timeframe, the Reinsurer Generali USA will report the net consideration as determined by the Ceding Company in the ReinsurerGenerali USA's tax return for the previous calendar year. (f) 5. If the Reinsurer Generali USA contests the Ceding Company's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount within thirty (30) days of the date the Reinsurer Generali USA submits its alternative calculation. If the Ceding Company and the Reinsurer Generali USA reach an agreement on an amount of net consideration, each party will report the agreed upon amount in its tax return for the previous calendar year. (g) 6. Both the Ceding Company and the Reinsurer Generali USA 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.