Attached files
| file | filename |
|---|---|
| EX-1.1 - UNDERWRITING AGREEMENT - BERKLEY W R CORP | wr40497532b.htm |
| 8-K - FORM 8K - BERKLEY W R CORP | wr40497532a.htm |
Exhibit 8.1
 |
787 Seventh Avenue
New York, NY 10019-6099 Tel: 212 728 8000 Fax: 212 728 8111 |
February 4, 2021
W. R. Berkley Corporation
475 Steamboat Road
Greenwich, Connecticut 06830
Re: W. R. Berkley
Corporation – 4.125% Subordinated Debentures due 2061
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 $300 million in aggregate principal amount of its 4.125% Subordinated Debentures due 2061 (the “Securities”), as described in the prospectus supplement, filed with the Securities and Exchange Commission on February 4, 2021 (the “Prospectus Supplement”), to the prospectus included in the Registration Statement on Form S-3 (File No. 333-249950) under the Securities Act of 1933, as amended (the “Securities Act”), dated November 6, 2020.
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 Company’s 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
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