Common use of DEFERRED ACQUISITION COST TAX Clause in Contracts

DEFERRED ACQUISITION COST TAX. The parties hereby agree to the following in accordance with Internal Revenue Regulation 1.848(g)(8) issued December 29, 1992 under Section 848 of the Internal Revenue Code: · to exchange information pertaining to the amount of net consideration under this Agreement not later than May 1st for each and every taxable year for which this treaty is in effect; and · that the party with net positive consideration, as defined in the regulations promulgated under Internal Revenue Code Section 848, will capitalize specific policy acquisition expenses with respect to this agreement without regard to the general deductions limitation of Internal Revenue Code Section 848(c)(1); and · that the other party may challenge such calculation within ten (10) business days of receipt of the such net positive consideration calculation; and · that should the other party challenge such calculation and the parties are unable to agree as to the appropriate methodology they shall refer such dispute to an outside tax consultant neutral to the parties; with such incurred expense equally borne by the parties.. Both the Company and the Reinsurer represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the Internal Revenue Code of 1986, as amended.

DEFERRED ACQUISITION COST TAX. The parties hereby agree to make the following election in accordance with Internal Revenue Treasury Regulation 1.848(g)(8section 1.848-2(g)(8) issued and further agree: a. This election shall take effect for the taxable year ending December 2931, 1992 under Section 848 of the Internal Revenue Code: · to exchange information pertaining to the amount of net consideration 2006 and shall remain in effect for each taxable year during which transactions covered under this Agreement not later than May 1st for each and every taxable year for which this treaty is in effectare applied; and · that and b. That the party with net positive consideration, as defined in the regulations promulgated under Internal Revenue Code Section 848, will capitalize specific policy acquisition expenses with respect to this agreement without regard to the general deductions limitation of Internal Revenue Code Section 848(c)(1); and · that and c. That the other party may challenge such calculation within ten _______ (10__) business days of receipt of the such net positive consideration calculation; and · that and d. That should the other party challenge such calculation and the parties are unable to agree as to the appropriate methodology they shall refer such dispute to an outside tax consultant neutral to the parties; with such incurred expense equally borne by both parties will share the parties.. costs of the independent tax consultant. Both the Company and the Reinsurer represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1, or Subpart F of Subchapter N of Chapter 1 of the Internal Revenue Code of 1986, as amended.

DEFERRED ACQUISITION COST TAX. The parties hereby agree to the following in accordance with Internal Revenue Regulation 1.848(g)(8) issued December 29, 1992 under Section 848 of the Internal Revenue Code: · to exchange information pertaining to the amount of net consideration under this Agreement not later than May 1st for each and every taxable year for which this treaty is in effect; and · that the party with net positive consideration, as defined in the regulations promulgated under Internal Revenue Code Section 848, will capitalize specific policy acquisition expenses with respect to this agreement Agreement without regard to the general deductions limitation of Internal Revenue Code Section 848(c)(1848(cX1); and · that the other party may challenge such calculation within ten (10) business days of receipt of the such net positive consideration calculation; and · that should the other party challenge such calculation and the parties are unable to agree as to the appropriate methodology they shall refer such dispute to an outside tax consultant neutral to the parties; with such incurred expense equally borne by the parties.. Both the Company and the Reinsurer represent and warrant that they are subject to U.S. taxation under either Subchapter L of Chapter 1I, or Subpart F of Subchapter N of Chapter 1 of the Internal Revenue Code of 1986, as amended.