Email from Winged Keel Group (EFTA01469000)

TO: FROM: Winged Keel Group, Inc. Richard L. Reinhold David 3. McCabe Catherine A. Harrington Tyler H. Ladner RE: DATED: U.S. Tax Treatment of Private Placement Variable Annuity August 2011 The following memorandum addresses the general U.S. federal income tax treatment of a U.S. individual owning a private placement variable annuity ("PPVA") to be issued by an insurance company (the "Insurance Company"). SUMMARY Generally the owner or beneficiary of the PPVA will not have taxabl