TAX NEUTRALITY. The parties to the Agreement contemplate that as a result of or concurrent with the transfer of assets and liabilities contemplated hereby, the GSIA shall become entitled to a refund of certain taxes, and that the Reinsurer shall sustain a corresponding tax liability. Accordingly, and in order to render the transaction tax-neutral as to such refund, the GSIA hereby disavows any right to collect any tax refund to which it currently is or may become entitled, and assigns its rights to any such tax refund to the Reinsurer.
Appears in 5 contracts
Samples: Loss Portfolio Transfer Assumption Reinsurance Agreement (Riscorp Inc), Transfer Assumption Reinsurance Agreement (Riscorp Inc), Transfer Assumption Reinsurance Agreement (Riscorp Inc)