Common use of Federal Taxes Clause in Contracts

Federal Taxes. 1. The Company and North American Re hereby agree to the following pursuant to Section 1.848-2 (g) (8) of the Income Tax Regulation issued December 1992, under Section 848 of the Internal Revenue Code of 1986, as amended. This election shall be effective as of the Effective Date of this Agreement and for all subsequent taxable years for which this Agreement remains in effect. (a) The term “party” will refer to either the Company or North American Re as appropriate. (b) The terms used in this Article are defined by reference to Regulation 1.848-2 in effect December 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 Company will submit a schedule to North American 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 stating that the Company will report such net consideration in its tax return for the preceding calendar year. (f) North American Re may contest such calculation by providing an alternative calculation to the Company by June 1. If North American Re does not so notify the Company, the Company will report the net consideration as determined by the Company in the Company’s tax return for the previous calendar year. (g) If North American Re contests the Company’s calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount by July 1. If the Company and North American Re 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. 2. North American Re and the Company represent and warrant that they are subject to U.S. taxation under Subchapter L of Chapter 1 of the Internal Revenue Code.

Federal Taxes. 1. The Company and North American Swiss Re America hereby agree to the following pursuant to Section 1.848-2 (g2(g)(8) (8) of the Income Tax Regulation issued December 1992, under Section 848 of the Internal Revenue Code of 1986, as amended. This election shall be effective as of the Effective Date of this Agreement and for all subsequent taxable years for which this Agreement remains in effect. (a) The term “party” will refer to either the Company or North American Swiss Re America, as appropriate. (b) The terms used in this Article are defined by reference to Regulation 1.848-2 in effect December 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) (1848(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 Company will submit a schedule to North American Swiss Re America 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 stating that the Company will report such net consideration in its tax return for the preceding calendar year. (f) North American Swiss Re America may contest such calculation by providing an alternative calculation to the Company by June 1. If North American Swiss Re America does not so notify the Company, the Company will report the net consideration as determined by the Company in the Company’s tax return for the previous calendar year. (g) If North American Swiss Re America contests the Company’s calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount by July 1. If the Company and North American Swiss Re America 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. 2. North American Swiss Re America and the Company represent and warrant that they are subject to U.S. taxation under Subchapter L of Chapter 1 of the Internal Revenue Code.

Federal Taxes. 1. The Company and North American Swiss Re America hereby agree to the following pursuant to Section 1.848-2 (g2(g)(8) (8) of the Income Tax Regulation issued December 1992, under Section 848 of the Internal Revenue Code of 1986, as amended. This election shall be effective as of the Effective Date of this Agreement and for all subsequent taxable years for which this Agreement remains in effect. (a) The term “"party” " will refer to either the Company or North American Swiss Re America as appropriate. (b) The terms used in this Article are defined by reference to Regulation 1.848-2 in effect December 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) (1848(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 Company will submit a schedule to North American Swiss Re America 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 stating that the Company will report such net consideration in its tax return for the preceding calendar year. (f) North American Swiss Re America may contest such calculation by providing an alternative calculation to the Company by June 1. If North American Swiss Re America does not so notify the Company, the Company will report the net consideration as determined by the Company in the Company’s 's tax return for the previous calendar year. (g) If North American Swiss Re America contests the Company’s 's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the SWISS RE AMERICA correct amount by July 1. If the Company and North American Swiss Re America 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. 2. North American Swiss Re America and the Company represent and warrant that they are subject to U.S. taxation under Subchapter L of Chapter 1 of the Internal Revenue Code.. SWISS RE AMERICA

Federal Taxes. 1. The Company and North American Re hereby agree to the following pursuant to Section 1.848-2 (g2(g)(8) (8) of the Income Tax Regulation issued December 1992, under Section 848 of the Internal Revenue Code of 1986, as amended. This election shall be effective as of the Effective Date of this Agreement and for all subsequent taxable years for which this Agreement remains in effect. (a) The term “"party” " will refer to either the Company or North American Re as appropriate. (b) The terms used in this Article are defined by reference to Regulation 1.848-2 in effect December 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) (1848(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 Company will submit a schedule to North American 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 stating that the Company will report such net consideration in its tax return for the preceding calendar year. (f) North American Re may contest such calculation by providing an alternative calculation to the Company by June 1. If North American Re does not so notify the Company, the Company will report the net consideration as determined by the Company in the Company’s 's tax return for the previous calendar year. (g) If North American Re contests the Company’s 's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount by July 1. If the Company and North American Re 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. 2. North American Re and the Company represent and warrant that they are subject to U.S. taxation under Subchapter L of Chapter 1 of the Internal Revenue Code.

Federal Taxes. 1. The Company and North American Re hereby agree to the following pursuant to Section 1.848-2 (g2(g)(8) (8) of the Income Tax Regulation issued December 1992, under Section 848 of the Internal Revenue Code of 1986, as amended. This election shall be effective as of the Effective Date of this Agreement and for all subsequent taxable years for which this Agreement remains in effect. (a) The term “party” will refer to either the Company or North American Re as appropriate. (b) The terms used in this Article are defined by reference to Regulation 1.848-2 in effect December 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(c848 (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 Company will submit a schedule to North American 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 stating that the Company will report such net consideration in its tax return for the preceding calendar year. (f) North American Re may contest such calculation by providing an alternative calculation to the Company by June 1. If North American Re does not so notify the Company, the Company will report the net consideration as determined by the Company in the Company’s tax return for the previous calendar year. (g) If North American Re contests the Company’s calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount by July 1. If the Company and North American Re 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. 2. North American Re and the Company represent and warrant that they are subject to U.S. taxation under Subchapter L of Chapter 1 of the Internal Revenue Code.

Federal Taxes. 1. The Company and North American Swiss Re America hereby agree to the following pursuant to Section 1.848-2 (g2(g)(8) (8) of the Income Tax Regulation issued December 1992, under Section 848 of the Internal Revenue Code of 1986, as amended. This election shall be effective as of the Effective Date of this Agreement and for all subsequent taxable years for which this Agreement remains in effect. (a) The term “"party” " will refer to either the Company or North American Swiss Re America as appropriate. (b) The terms used in this Article are defined by reference to Regulation 1.848-2 in effect December 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) (1848(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 Company will submit a schedule to North American Swiss Re America 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 stating that the Company will report such net consideration in its tax return for the preceding calendar year. (f) North American Swiss Re America may contest such calculation by providing an alternative calculation to the Company by June 1. If North American Swiss Re America does not so notify the Company, the Company will report the net consideration as determined by the Company in the Company’s 's tax return for the previous calendar year. (g) If North American Swiss Re America contests the Company’s 's calculation of the net consideration, the parties will act in good faith to reach an agreement as to the correct amount by July 1. If the Company and North American Swiss Re America reach agreement on an amount SWISS RE AMERICA of the net consideration, each party shall report such amount in their respective tax returns for the previous calendar year. 2. North American Swiss Re America and the Company represent and warrant that they are subject to U.S. taxation under Subchapter L of Chapter 1 of the Internal Revenue Code.. SWISS RE AMERICA