Federal Tax Opinion. The Company shall have received an opinion of Rosenman & Colin LLP (the "Company's Counsel"), in form and substance reasonably satisfactory to the Company, dated as of the Effective Time, substantially to the effect that, on the basis of facts, representations and assumptions set forth in such opinion which are consistent with the state of facts existing at the Effective Time, the Merger will be treated as a reorganization within the meaning of Section 368(a) of the Code and that, accordingly, for federal income tax purposes:
Appears in 2 contracts
Samples: Agreement and Plan of Merger (Oxford Resources Corp), Agreement and Plan of Merger (Barnett Banks Inc)
Federal Tax Opinion. The Company shall have received an opinion of Rosenman Xxxxxx, Feinblatt, Rothman, Hoffberger & Colin LLP Xxxxxxxxx, LLC (the "Company's Counsel"), in form and substance reasonably satisfactory to the Company, dated as of the Effective Time, substantially to the effect that, on the basis of facts, representations and assumptions set forth in such opinion which are consistent with the state of facts existing at the Effective Time, the Merger and the Subsidiary Merger will be treated as a reorganization reorganizations within the meaning of Section 368(a) of the Code and that, accordingly, that accordingly for federal income tax purposes:
Appears in 2 contracts
Samples: Agreement and Plan of Merger (Patapsco Valley Bancshares Inc), Agreement and Plan of Merger (F&m Bancorp)
Federal Tax Opinion. The Company shall have received an opinion of Rosenman from Gerrxxx & Colin LLP XcCrxxxx, X.C. (the "Company's Counsel"), in form and substance reasonably satisfactory to the Company, dated as of the Effective Time, substantially to the effect that, on the basis of facts, representations and assumptions set forth in such opinion which are consistent with the state of facts existing at the Effective Time, the Merger will be treated as a reorganization within the meaning of Section 368(a) of the Code and that, accordingly, for federal income tax purposes:
Appears in 2 contracts
Samples: Agreement and Plan of Merger (Bancorpsouth Inc), Agreement and Plan of Merger (Merchants Capital Corp /MS/)
Federal Tax Opinion. The Company shall have received an opinion of Rosenman Weil, Gotshal & Colin Manges LLP (the "Company's Counsel"), in form and substance reasonably satisfactory reasonabxx xxxisfactory to the Company, dated as of the Effective Time, substantially to the effect that, on the basis of facts, representations and assumptions set forth in such opinion which are consistent with the state of facts existing at the Effective Time, the Merger will be treated as a reorganization within the meaning of Section 122 368(a) of the Code and that, that accordingly, for federal income tax purposes:
Appears in 1 contract
Samples: Agreement and Plan of Merger (New York Bancorp Inc)
Federal Tax Opinion. The Company shall have received an opinion of Rosenman from Skadden, Arps, Slate, Xxxxxxx & Colin Xxxx LLP (the "Company's Counsel"), in form and substance reasonably satisfactory to the Company, dated as of the Effective Time, substantially to the effect that, on the basis of facts, representations and assumptions set forth in such opinion which are consistent with the state of facts existing at the Effective Time, the Merger will be treated as a reorganization within the meaning of Section 368(a) of the Code and that, accordingly, for federal income tax purposes:
Appears in 1 contract
Samples: Agreement and Plan of Merger (Dime Community Bancshares Inc)
Federal Tax Opinion. The Company shall have received an opinion of Rosenman from Skadden, Arps, Slate, Meagher & Colin Flom LLP (the "Company's Counsel"), in form and substance reasonably xxxxxxxce xxxxonably satisfactory to the Company, dated as of the Effective Time, substantially to the effect that, on the basis of facts, representations and assumptions set forth in such opinion which are consistent with the state of facts existing at the Effective Time, the Merger will be treated as a reorganization within the meaning of Section 368(a) of the Code and that, accordingly, for federal income tax purposes:
Appears in 1 contract
Samples: Agreement and Plan of Merger (Deposit Guaranty Corp)
Federal Tax Opinion. The Company shall have received an opinion of Rosenman from XxXxxxxx & Colin English LLP (the "Company's Counsel"), in form and substance reasonably satisfactory to the Company, dated as of the Effective Time, substantially to the effect that, on the basis of facts, representations and assumptions set forth in such opinion which are consistent with the state of facts existing at the Effective Time, the Merger will be treated as a reorganization within the meaning of Section 368(a) of the Code and that, accordingly, for federal income tax purposes:
Appears in 1 contract
Samples: Agreement and Plan of Merger (Statewide Financial Corp)
Federal Tax Opinion. The Company shall have received an opinion of Rosenman from Bradxxx Xxxxx Xxxe & Colin White LLP (the "Company's Counsel"), in form and substance reasonably satisfactory to the Company, dated as of the Effective Time, substantially to the effect that, on the basis of facts, representations and assumptions set forth in such opinion which are consistent with the state of facts existing at the Effective Time, the Merger will be treated as a reorganization within the meaning of Section 368(a) of the Code and that, accordingly, for federal income tax purposes:
Appears in 1 contract
Federal Tax Opinion. The Company shall have received an opinion of Rosenman from Jenkens & Colin LLP Gilcxxxxx (the xxe "Company's Counsel"), in form and substance reasonably satisfactory to the Company, dated as of the Effective Time, substantially to the effect that, on the basis of facts, representations and assumptions set forth in such opinion which are consistent with the state of facts existing at the Effective Time, the Merger will be treated as a reorganization within the meaning of Section 368(a) of the Code and that, accordingly, for federal income tax purposes:
Appears in 1 contract
