TAX SHARING AGREEMENT

Tax Allocation or Sharing Agreement

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This Tax Allocation or Sharing Agreement involves

ING America Insurance Holdings Inc | ReliaStar Life Insurance Company | Lion Connecticut Holdings Inc.

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Title: TAX SHARING AGREEMENT
Date: 5/12/2006

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Exhibit 10.(a)

TAX SHARING AGREEMENT

THIS AGREEMENT is entered into by and among ING America Insurance Holdings Inc. (“ING AIH”), ReliaStar Life Insurance Company of New York (the “Subsidiary”), ReliaStar Life Insurance Company (“RLIC”) and Lion Connecticut Holdings Inc. (“Lion”). Each of RLIC and Lion is the direct or indirect parent corporation of the Subsidiary, is a member of the ING AIH affiliated group pursuant to a tax sharing agreement other than this Agreement, and joins in this agreement as a signatory and not as a participant in this Agreement.

WITNESSETH:

WHEREAS, effective January 1, 2006 ING AIH and the Subsidiary will be members of an affiliated group as that term is defined in Section 1504 of the Internal Revenue Code of 1986, as amended (the "Code"), which consists of ING AIH, the Subsidiary, and certain other subsidiaries of ING AIH, and which expects to file a consolidated federal income tax return for each taxable year during which the Subsidiary is an includible corporation qualified to so file; and

WHEREAS, it is desirable for the Subsidiary and ING AIH to enter into this Tax Sharing Agreement ("Agreement") to provide for the manner of computation of the amounts and timing of payments with regard thereto by ING AIH to the Subsidiary and by the Subsidiary to ING AIH, and various related matters;

NOW, THEREFORE, in consideration of the agreements contained herein and of other good and valuable consideration, the receipt and sufficiency of which are hereby acknowledged, the parties hereby agree as follows:

1.	AMOUNT OF PAYMENTS

General - For each taxable year during which the Subsidiary is included in a consolidated federal income tax return with ING AIH, the Subsidiary will pay to ING AIH an amount equal to the regular federal income tax liability (including any interest, penalties and other additions to tax) that the Subsidiary would pay on its taxable income if it were filing a separate, unconsolidated return, provided that (i) Tax Assets (as defined herein) will be treated in accordance with subsection (b) of this section, (ii) intercompany transactions will be treated in accordance with income tax regulations governing intercompany transactions in consolidated returns and subject to any election which may be made by ING AIH with regard thereto; (iii) the Subsidiary's payment will be increased to the extent that the Subsidiary generates Other Taxes, as determined in accordance with subsection (d) of this section; (iv) such computation will be made as though the highest rate of tax specified in subsection (b) of Section 11 of the Code were the only rate set forth in that subsection, and (v) such computation shall reflect the positions, elections and accounting methods used by ING AIH in preparing the consolidated federal income tax return for ING AIH and its subsidiaries.

It is the intention of the parties that the tax charge to the Subsidiary under this agreement shall not be more than it would have paid if it had filed on a separate return basis. The Subsidiary shall be “paid” for any foreign tax credits, investment credits, losses or any loss carry over (“collectively herein referred to as credits) generated by it, to the extent actually used in the consolidated return. Payment shall be equal to the “savings” generated by its credits. All payments shall be recorded on the Subsidiary’s books as contributed surplus. Once the Subsidiary is “paid” for its credits, it cannot use such credits in the calculation of its tax liability under the separate return basis. Any of the Subsidiary’s credits which are not used in the consolidated return and for which it has not been paid shall be retained by the Subsidiary for possible future use.

Tax Assets - "Tax Asset" shall mean any net operating loss, net capital loss, investment tax credit, foreign tax credit, charitable deduction, dividends received deduction or any other deduction, credit or tax attribute, including carryovers and carrybacks of such attributes, which could reduce taxes. Except as provided in subsection (c) of this section, for each taxable year during which the Subsidiary is included in a consolidated federal income tax return with ING AIH, ING AIH will pay to the Subsidiary an amount equal to the tax benefit of the Subsidiary's Tax Assets to the extent such Tax Assets are utilized in the reduction of the consolidated federal income tax liability of the ING AIH group. The extent to which Tax Assets are actually utilized will be determined in accordance with Income Tax Regulations Sections 1.1552-1(a)(2) and 1.1502-33(d)(3).

Separate Return Years - To the extent any portion of a Tax Asset of the affiliated group is carried back to a pre-consolidation separate return year of the Subsidiary (whether by operation of law or at the discretion of ING AIH) the Subsidiary shall not be entitled to payment from ING AIH with respect thereto. This shall be the case whether or not the Subsidiary actually receives payment for the benefit of such Tax Asset from the Internal Revenue Service ("IRS") or from the parent of a former affiliated group.

Other Taxes - For any taxable year in which the affiliated group incurs taxes (other than the alternative minimum tax) such as ITC recapture, environmental tax, etc. (“Other Taxes”), such taxes, to the extent directly allocable to the Subsidiary, will be paid by the Subsidiary. To the extent such taxes are not directly allocable to the Subsidiary, such taxes will be paid by the Subsidiary in the proportion that its share of such attributes giving rise to the tax liability bears to the affiliated group’s total amount of such attributes.

Alternative minimum tax ("AMT") and Related minimum tax credit ("MTC") - For any taxable year in which the affiliated group incurs an AMT or utilizes a MTC, the Subsidiary shall pay to, or receive from, ING AIH such AMT or MTC amount respectively to the extent it produces the attributes giving rise to the AMT or MTC. The calculation of the AMT or MTC shall be subject to a methodology determined by ING AIH in its sole discretion, provided, however, that any method adopted by ING AIH shall not be changed without prior notification to the Subsidiary. Any payments required under this subsection are in addition to payments required under the previous subsections.

2.	INSTALLMENT PAYMENTS

Determination and Timing - During and following a taxable year in which the Subsidiary is included in a consolidated federal income tax return with ING AIH , it shall pay to ING AIH, or receive from ING AIH, as the case may be, installment payments of the amount determined pursuant to section 1 of this Agreement. All settlements under the Agreement shall be made within 30 days of the filing of the