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1 ATTORNEY BIOGRAPHY Saren Goldner Partner New York P: E: Education J.D., State University of New York at Buffalo Law School B.A., summa cum laude, University of Massachusetts Bar Admissions District of Columbia New York Background Saren Goldner focuses her practice on international tax, insurance, reinsurance and insurance tax issues, including structuring non-u.s. operations, captive insurance companies, insurance characterization and other insurance specific tax issues. She advises clients on public and private securities offerings (including securitizations and catastrophe bonds), the structuring of international insurance operations, (including the application of tax treaties, FATCA, the CFC, and PFIC rules and other tax issues arising as a result of cross border operations), the formation and operation of captives and cell companies and tax exempt issues. Saren was tax counsel at a large international law firm before joining Eversheds Sutherland (US). In addition, she served as a judicial clerk for the Honorable Herbert L. Chabot at the United States Tax Court. Experience Advised non-u.s. insurers on formation, restructurings, IPOs and other securities offerings, including sidecars and catastrophe bond issuances. Advised investors on insurance investments. Represented a reinsurance-linked securities fund in its formation and restructuring. Provided U.S. tax advice on forming a member at Lloyd's of London. Provides U.S. tax advice on catastrophe bond issuances. Represented a Bermuda reinsurance company in its structuring and formation, the private offering of its securities, and the establishment of its business. Represented client in IRS audit and appeal. Articles Pooling An Analysis of Best Practices (March 2019)

2 PAGE 2 International Regulatory and Legislative Update (March 2019) Are You An Inadvertent US Shareholder In A Foreign Corp? (October 19, 2018) Law360 Preparing For New Life Settlement Transactions Reporting (September 18, 2018) Law360 New NJ Direct Placement Tax Decision (August 2018) Tax Court Issues in Small Insurance Company Case (August 2018) 953(d) Elections: A Real Problem or Is the IRS Making Them a Problem? (June 2018) (CICR) Captive Insurers and the Base Erosion Anti-Abuse Tax (January 26, 2018) IRS Rules on Revocation of Section 953(d) Election (December 2017) A Tax Court Opinion in Avrahami Finally (October 2017) State Tax Developments: Captives (September 2017) IRS Addresses Insurance Characterization (August 2017) New York Adopts Cybersecurity Requirements (April 2017) What Is a Reciprocal Insurance Company, and How Is It Taxed? (March 1, 2017) Direct Procurement Taxes: A Primer for Captives (February 22, 2017) Group Captives, Cell Captives, and Risk Pooling Arrangements Guide (February 1, 2017) What Is FATCA, and How Do Captives Handle It? (January 18, 2017) Taxation of Single-Parent Captives: A Basic Guide (January 12, 2017)

3 PAGE 3 When are Premiums Paid to a Captive Insurance Company Deductible for Federal Income Tax Purposes? (January 4, 2017) Section 831(b) Captives as Transactions of Interest (January 2017) Mortgage Insurance Captives Perhaps a New Life? (January 2017) Final and Temporary Section 385 Regulations (December 2016) Ceding Commission Held Amortizable in Reinsurance Transaction (December 2016) Disclosure of 831(b) Transactions of Interest Required by IRS in Notice (November 3, 2016) New York State Rules on Premium Deduction (September 2016) New Proposed Section 385 Regulations (August 1, 2016) Nonprofit Insurance Program Ruled Not Exempt (July 2016) New York Court Rules on Premium Deduction (June 2016) IRS: Status of Coverages (May 2016) A Look at the IRS Position in Avrahami (March 2016) IRS Revokes Cascading Excise Tax Ruling (February 2016) Congress Amends Section 831(b) (February 2016) Residual Value Insurance Qualifies as Insurance for Tax Purposes (December 2015) IRS on PFIC Regulations for Hedge Fund Reinsurers (November 2015)

4 PAGE 4 Domicile Considerations (October 2015) Treasury and the IRS Offer a New Take on the PFIC Active Insurance Exception (September 2015) TerraLex Connections Validus Affirmed for All the Right Reasons The FET Does Not Apply to Wholly Foreign Reinsurance Transactions (September 2015) TerraLex Connections Senator Wyden Introduces PFIC Legislation (September 2015) Commerce Department Survey Response Deadline Passes Quietly (August 2015) Captive Insurance Company Report Validus Result Affirmed on Narrower Grounds (July 2015) Deadline Imminent for Response to Commerce Department Survey (June 26, 2015) FATCA Key Points to Remember for Captives (June 2015) Validus Court Holds FET Not Applicable to Foreign Reinsurance (May 27, 2015) Treasury and IRS Issue New Proposed PFIC Regulations Aimed at Hedge Fund Reinsurers (May 6, 2015) The Insured Roll Up Where Are We? (May 2015) 831(b) Companies (April 6, 2015) Bloomberg Law Tax Management Memorandum IRS Says Currency Fluctuation Cover is Not Insurance for Tax Purposes (April 6, 2015) Healthmark Case Changes Brother-Sister Captive Tax Treatment (April 6, 2015) IRS Dirty Dozen Abusive Tax Structures Single Out Micro-Captives (February 6, 2015) Captive Wire

5 PAGE 5 The Tax Court Decides Two New Captive Cases (February 2015) Tax Court Pending and Newly Issued Captive Cases (December 2014) FATCA Implementation for Property and Casualty Insurers (September 29, 2014) Tax Notes FATCA Regs Come Up Short for P&C Insurance Industry (March 10, 2014) Law360 Finally: A Rent-a-Center Decision (March 2014) CAPTIVE INSURANCE COMPANY REPORTS Money Market Funds, Withholding Tax, and Tax Extenders (January 2014) Best's Review New Rules for the New Year (January 2014) IRS: Positive FATCA News for Captives (December 2013) Bruce Wright Updates an Offshore Tax Case (July 2013) Guide to FATCA for Foreign Captives (March 2013) Tax Implications of Risk Financing (2013) Risk Financing, a Guide to Insurance Cash Flow The House Always Wins: Treasury and the IRS Offer a Loaded Deck of Regulations Addressing Global Reshuffling (2012) Bloomberg BNA Tax and Accounting Center Proposed U.S. Federal Tax Legislation - Impact on Cayman Islands Captives (January 5, 2010) Cayman Financial Review Presentations Captive Insurance Tax Forum (February 25, 2019) Base erosion and anti-avoidance tax (BEAT) (December 14, 2018) GW/IRS 31 st Annual Institute on Current Issues in International Taxation Captive Insurance Tax Forum (October 29-30, 2018)

6 PAGE 6 Webcast: Section 953(d) Elections The Election Process May Not Be as Easy as It Appears (August 16, 2018) American Bar Association Eversheds Sutherland Year-End Tax Seminar (November 10, 2017) Tax Aspects of Offshore Captives ( October 25, 2017) The Secret Life of Captives (September 29, 2016) American Bar Association Tax Developments on the Use of Cat Bonds (May 2014) Federal Bar Association 26th Annual Insurance Tax Seminar Definition of Insurance Update (January 2013) ABA Tax Section Insurance Committee Meeting Books Chapter 4: US Taxation of Non-US Captives (Spring 2018 ) Captive Insurance Deskbook for the Business Lawyer published by the American Bar Association Appendix: The Base Erosion Anti Abuse Tax (BEAT) Overview (Spring 2018) Captive Insurance Deskbook for the Business Lawyer published by the American Bar Association Clerkships Honorable Herbert L. Chabot, United States Tax Court