FEDERAL INCOME TAX LAWS. The Corporation has obtained an opinion of Proskauer Rose LLP stating that, under existing federal income tax laws and regulations, assuming the Company acts as described in the “Federal Income Tax Considerations” section of the Prospectus and timely files the requisite elections, counsel is of the opinion that the Company has been organized in conformity with the requirements for qualification as a REIT beginning with its taxable year ending December 31, 2009, and that its prior, current and anticipated methods of operation (as described in the Prospectus and represented by management) has enabled and should enable it to satisfy the REIT Requirements (as defined in the Prospectus).
FEDERAL INCOME TAX LAWS. The Corporation has obtained an opinion of Xxxxx Xxxxxx LLP, Philadelphia, Pennsylvania, stating that, under existing federal income tax laws and regulations, assuming the Company acts as described in the "Federal Income Tax Considerations" section of the Prospectus and timely files the requisite elections, counsel is of the opinion that the Company has been organized in conformity with the requirements for qualification as a REIT beginning with its taxable year ending December 31, 2003, and that its prior, current and anticipated methods of operation (as described in the Prospectus and represented by management) has enabled and should enable it to satisfy the REIT Requirements (as defined in the Prospectus).
FEDERAL INCOME TAX LAWS. The Company has obtained an opinion of Xxxxxxx & Xxxxxxxx Ltd., Chicago, Illinois, stating that, under existing federal income tax laws and regulations, assuming the Company acts as described in the “Federal Income Tax Considerations” section of the Prospectus and timely files the requisite elections, counsel is of the opinion that the Company has been organized in conformity with the requirements for qualification as a REIT beginning with its taxable year ending December 31, 2009, and that its method of operation (as described in the Prospectus and represented by management) should enable the Company to satisfy the requirements for qualifying as a REIT.
FEDERAL INCOME TAX LAWS. The Company has obtained an opinion of Xxxxxxx & Xxxxxxxx Ltd., Chicago, Illinois, stating that, under existing federal income tax laws and regulations, assuming the Company acts as described in the “Federal Income Tax Considerations” section of the Prospectus (and as represented to Xxxxxxx & Xxxxxxxx Ltd. by the Company) and timely files the requisite elections, counsel is of the opinion that the Company has been organized in conformity with the requirements for qualification as a real estate investment trust (a “REIT”) beginning with its taxable year ending December 31, 2012, and that its method of operation (as described in the Prospectus and represented by management) should enable the Company to satisfy the requirements for qualifying as a REIT.
FEDERAL INCOME TAX LAWS. The Company has obtained an opinion of counsel stating that, under existing federal income tax laws and regulations, assuming the Company acts as described in the “U.S. Federal Income Tax Considerations” section of the Prospectus and that its prior, current and anticipated methods of operation (as described in the Prospectus and represented by management).
FEDERAL INCOME TAX LAWS. The Seller has obtained an opinion from its tax counsel stating that, subject to the qualifications, assumptions and limitations set forth therein, under existing federal income tax laws and regulations, counsel is of the opinion that the purchase of the Interests by the Investors in the Trust as described in the Private Placement Memorandum should lead to the Interests being classified as undivided Interests in real estate under Section 1031 of the Internal Revenue Code.
FEDERAL INCOME TAX LAWS. The Corporation has obtained an opinion of Katten Muchin Zavis Rosenman stating that, under existing federal xxxxxx xxx lxxx xxx xxxxxxtions, assuming the Company acts as described in the "Federal Income Tax Considerations" section of the Prospectus and timely files the requisite elections, counsel is of the opinion that the Company has been organized in conformity with the requirements for qualification as a REIT beginning with its taxable year ending December 31, 1999, and that its prior, current and anticipated methods of operation (as described in the Prospectus and represented by management) has enabled and should enable it to satisfy the REIT Requirements (as defined in the Prospectus).
FEDERAL INCOME TAX LAWS. The Company has obtained an opinion of Xxxxxxx & Xxxxxxxx Ltd., Chicago, Illinois, stating that, in its opinion, commencing with the taxable year that ended December 31, 2005, the Company was organized in conformity with the requirements for qualification as a REIT under the Internal Revenue Code of 1986, as amended (the “Code”), and the Company’s actual method of operation through the date of the opinion has enabled, and its proposed method of operation will enable, the Company to meet the requirements for qualification and taxation as a REIT. As noted in the Registration Statement, the Company’s qualification and taxation as a REIT depend upon its ability to meet, through actual annual operating results, certain requirements including requirements relating to distribution levels and diversity of stock ownership, and the various qualification tests imposed under the Code, the results of which were not, and will not be, reviewed by counsel. Accordingly, no assurance can be given by counsel that the actual results of the Company’s operation for any one taxable year will satisfy the requirements for taxation as a REIT under the Code.
FEDERAL INCOME TAX LAWS. The Corporation has obtained an opinion of Wildman, Harrold, Xxxxx & Xxxxx stating that, under existing federal income tax laws and regulations, assuming the Company acts as described in the "Federal Income Tax
FEDERAL INCOME TAX LAWS. The Corporation has obtained an opinion of Shefxxx & Xroexxxx Xxx. stating that, under existing federal income tax laws and regulations, assuming the Company acts as described in the "Federal Income Tax Considerations" section of the Prospectus and timely files the requisite elections, counsel is of the opinion that the Company has been organized in conformity with the requirements for qualification as a REIT beginning with its taxable year ending December
