Common use of Federal Tax Opinion Clause in Contracts

Federal Tax Opinion. FNB shall have received the opinion of its tax counsel, Xxxx Xxxxx LLP, in form and substance reasonably satisfactory to FNB, dated the Closing Date, to the effect that, on the basis of facts, representations and assumptions set forth in such opinion, the Merger will qualify for the Intended Tax Treatment. In rendering such opinion, counsel may require and rely upon representations contained in Tax Representation Letters executed by officers of MBI and FNB.

Federal Tax Opinion. FNB shall have received the written opinion of its tax counsel, Xxxx Xxxxx LLP, in form and substance reasonably satisfactory to FNB, dated the Closing Date, to the effect that, on the basis of facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify for as a “reorganization” within the Intended Tax Treatmentmeaning of Section 368(a) of the Code. In rendering such opinion, counsel may require and rely upon representations contained in Tax Representation Letters executed by officers of MBI HBI and FNB.

Federal Tax Opinion. FNB shall have received the opinion of its tax counsel, Xxxx Xxxxx LLP, in form and substance reasonably satisfactory to FNB, dated the Closing Date, to the effect that, on the basis of facts, representations and assumptions set forth in such opinion, the Merger will qualify for be treated as a reorganization within the Intended Tax Treatmentmeaning of Section 368(a) of the Code. In rendering such opinion, counsel may require and rely upon representations contained in Tax Representation Letters executed by officers of MBI PVFC and FNB.

Federal Tax Opinion. FNB shall have received the opinion of its tax counsel, Xxxx Xxxxx LLP, in form and substance reasonably satisfactory to FNB, dated the Closing Date, to the effect that, on the basis of facts, representations and assumptions set forth in such opinion, the Merger will qualify for be treated as a reorganization within the Intended Tax Treatmentmeaning of Section 368(a) of the Code. In rendering such opinion, counsel may require and rely upon representations contained in Tax Representation Letters executed by certificates of officers of MBI ANNB and FNB, reasonably satisfactory in form and substance to it.

Federal Tax Opinion. FNB shall have received the opinion of its tax counsel, Xxxx Xxxxx Xxxxxx LLP, in form and substance reasonably satisfactory to FNB, dated the Closing Date, to the effect that, on the basis of facts, representations and assumptions set forth in such opinion, the Merger will qualify for be treated as a reorganization within the Intended Tax Treatmentmeaning of Section 368(a) of the Code. In rendering such opinion, counsel may require and rely upon representations contained in Tax Representation Letters executed by certificates of officers of MBI CBI and FNB, reasonably satisfactory in form and substance to it.

Federal Tax Opinion. FNB shall have received the opinion of its tax counsel, Xxxx Xxxxx LLP, in form and substance reasonably satisfactory to FNB, dated the Closing Date, to the effect that, on the basis of facts, representations and assumptions set forth in such opinion, the Merger will qualify for be treated as a reorganization within the Intended Tax Treatmentmeaning of Section 368(a) of the Code. In rendering such opinion, counsel may require and rely upon representations contained in Tax Representation Letters executed by officers of MBI BCSB and FNB.

Federal Tax Opinion. FNB shall have received the written opinion of its tax counsel, Xxxx Xxxxx LLP, in form and substance reasonably satisfactory to FNB, dated the Closing Date, to the effect that, on the basis of facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify for as a “reorganization” within the Intended Tax Treatmentmeaning of Section 368(a) of the Code. In rendering such opinion, counsel may require and rely upon representations contained in Tax Representation Letters executed by officers of MBI YDKN and FNB.

Federal Tax Opinion. FNB shall have received the written opinion of its tax counsel, Xxxx Xxxxx LLP, in form and substance reasonably satisfactory to FNB, dated the Closing Date, to the effect that, on the basis of facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify for as a “reorganization” within the Intended Tax Treatmentmeaning of Section 368(a) of the Code. In rendering such opinion, counsel may require and rely upon representations contained in Tax Representation Letters executed by officers of MBI UBNC and FNB.

Federal Tax Opinion. FNB shall have received the opinion of its tax counsel, Xxxx Xxxxx Dxxxx Xxxxxx LLP, in form and substance reasonably satisfactory to FNB, dated the Closing Date, to the effect that, on the basis of facts, representations and assumptions set forth in such opinion, the Merger will qualify for be treated as a reorganization within the Intended Tax Treatmentmeaning of Section 368(a) of the Code. In rendering such opinion, counsel may require and rely upon representations contained in Tax Representation Letters executed by certificates of officers of MBI IRGB and FNB, reasonably satisfactory in form and substance to it.

Federal Tax Opinion. FNB shall have received the opinion of its tax counsel, Xxxx Xxxxx Dxxxx Xxxxxx LLP, in form and substance reasonably satisfactory to FNB, dated the Closing Date, to the effect that, on the basis of facts, representations and assumptions set forth in such opinion, the Merger will qualify for be treated as a reorganization within the Intended Tax Treatmentmeaning of Section 368(a) of the Code. In rendering such opinion, counsel may require and rely upon representations contained in Tax Representation Letters executed by certificates of officers of MBI Omega and FNB, reasonably satisfactory in form and substance to it.

Federal Tax Opinion. FNB shall have received the opinion of its tax counsel, Xxxx Xxxxx LLP, in form and substance reasonably satisfactory to FNB, dated the Closing Date, to the effect that, on the basis of facts, representations and assumptions set forth in such opinion, the Merger will qualify for be treated as a reorganization within the Intended Tax Treatmentmeaning of Section 368(a) of the Code. In rendering such opinion, counsel may require and rely upon representations contained in Tax Representation Letters executed by certificates of officers of MBI PFC and FNB, reasonably satisfactory in form and substance to it.

Federal Tax Opinion. FNB shall have received the written opinion of its tax counsel, Xxxx Rxxx Xxxxx LLP, in form and substance reasonably satisfactory to FNB, dated the Closing Date, to the effect that, on the basis of facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify for as a “reorganization” within the Intended Tax Treatmentmeaning of Section 368(a) of the Code. In rendering such opinion, counsel may require and rely upon representations contained in Tax Representation Letters executed by officers of MBI YDKN and FNB.

Federal Tax Opinion. FNB shall have received the opinion of its tax counsel, Xxxx Xxxxx LLP, in form and substance reasonably satisfactory to FNB, dated the Closing Date, to the effect that, on the basis of facts, representations and assumptions set forth in such opinion, the Merger will qualify for be treated as a reorganization within the Intended Tax Treatmentmeaning of Section 368(a) of the Code. In rendering such opinion, counsel may require and rely upon representations contained in Tax Representation Letters executed by officers of MBI OBA and FNB.