Attached files
file | filename |
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EX-1.1 - EX-1.1 - BERKLEY W R CORP | d34779dex11.htm |
8-K - 8-K - BERKLEY W R CORP | d34779d8k.htm |
Exhibit 8.1
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787 Seventh Avenue New York, NY 10019-6099 Tel: 212 728 8000 Fax: 212 728 8111 |
September 17, 2020
W. R. Berkley Corporation
475 Steamboat Road
Greenwich, Connecticut 06830
Re: W. R. Berkley Corporation 4.25% Subordinated Debentures due 2060
Ladies and Gentlemen:
We have acted as tax counsel to W. R. Berkley Corporation, a Delaware corporation (the Company), in connection with the issuance and sale of $250 million in aggregate principal amount of its 4.25% Subordinated Debentures due 2060 (the Securities), as described in the prospectus supplement, filed with the Securities and Exchange Commission on September 17, 2020 (the Prospectus Supplement), to the prospectus included in the Registration Statement on Form S-3 (File No. 333-221559) under the Securities Act of 1933, as amended (the Securities Act), dated November 14, 2017.
We hereby confirm to you our opinion as set forth under the heading Material United States Federal Income Tax Considerations in the Prospectus Supplement, subject to the limitations set forth therein.
We hereby consent to the filing of this opinion as an exhibit to the Companys Form 8-K to be filed in connection with the issuance and sale of the Securities, and to the reference to us under the heading Material United States Federal Income Tax Considerations in the Prospectus Supplement. In giving such consent, we do not thereby admit that we are in the category of persons whose consent is required under Section 7 of the Securities Act.
Very truly yours, |
/s/ Willkie Farr & Gallagher LLP |
NEW YORK WASHINGTON HOUSTON PALO ALTO SAN FRANCISCO CHICAGO PARIS LONDON FRANKFURT BRUSSELS MILAN ROME