Epstein Secrets

re not paid until the earnings are deemed repatriated to the United States. The timing of when earnings are repatriated was a matter of dispute with the Internal Revenue Service ("IRS"). The Company successfully litigated the matter related to the 1992 to 1994 years. For the 1995 to 2002 years, the Company and the IRS negot

Registration Statement on Form S-3 (File no. 333.105484) dated May 22, 2003. 4./ Proposed form of Debt Warrant Agreement for Warrants attached to Debt Securities, with proposed form of Debt Warrant Certificate incorporated by reference to Exhibit 4.2 to the Company's Registration Statement on Form S-3 (File

date of the debentures, the debentures will be treated as indebtedness for U.S. federal income tax purposes. However, there can be no assurance that the Internal Revenue Service ("IRS") or a court will agree with our determination. No ruling is being sought from the IRS on any of the issues discussed herein. S-24 EFTA_R1_0

30, (203) 629- 3000. 8-34 EFTA_R1_02074107 EFTA02702301 PROSPECTUS W. R. Berkley Corporation Common Stock, Preferred Stock, Depositary Shares, Debt Securities, Warrants to Purchase Common Stock, Warrants to Purchase Preferred Stock, Warrants to Purchase Debt Securities, Stock Purchase Contracts and Stock

dents of the United States) subject to special treatment under U.S. federal income tax law. We have not requested and will not request a ruling from the Internal Revenue Service (the "IRS") with respect to any of the U.S. federal income tax issues discussed below or in the accompanying prospectus. Prospective investors shou

ation of the indenture. A prospectus supplement may set forth modifications or additions to these provisions with respect to a particular series of Debt Securities. Concerning the Trustee The indenture provides that there may be more than one trustee under the indenture, each with respect to one or more serie