Opinion of Special Tax Counsel. The City and the Trustee may deviate from the provisions of this Tax Agreement if furnished with an Opinion of Special Tax Counsel addressed to each of them to the effect that the proposed deviation will not adversely affect the exclusion of the Interest Portion of the Basic Rent Payments represented by the Certificates from gross income for federal income tax purposes. The City and the Trustee will comply with any further or different instructions provided in an Opinion of Special Tax Counsel to the effect that the further or different instructions need to be complied with in order to maintain the validity of the Certificates or the exclusion from gross income of the Interest Portion of the Basic Rent Payments.
Opinion of Special Tax Counsel. The Parent Board shall have received an opinion of its special tax counsel at Hunton & Xxxxxxxx LLP in a form satisfactory to Parent that the Distribution will qualify as a transaction that is tax-free for U.S. federal income tax purposes under Section 355(a) of the Code, and such opinion shall not have been revoked or modified in any material respect.
Opinion of Special Tax Counsel. These Arbitrage Instructions may be modified or amended in whole or in part upon receipt of an opinion of Special Tax Counsel to the effect that such modifications and amendments will not adversely affect the exclusion from federal gross income of the interest components of the Lease Payments.
(a) Leasing Schedule #000-0000000-000 dated [Dated Date] (the "Lease"), by and between Siemens Public, Inc. (the "Lessor") and Carpinteria Valley Water District, as Lessee, which incorporates the terms and conditions of Master Lease Purchase Agreement dated [Dated Date] (the “Agreement”); (b) Escrow Agreement Relating to Equipment Subject to Leasing Schedule #000-0000000-000 dated [Dated Date] (the “Escrow Agreement”), among the Lessee, the Lessor and UMB Bank, N.A., as escrow agent; and
Opinion of Special Tax Counsel for the Offerors. The favorable opinion, dated such Date of Delivery, of Xxxxxxx & Xxxx, special tax counsel to the Offerors, in form and substance satisfactory to counsel for the Underwriter, relating to the Optional Preferred Securities to be purchased on such Date of Delivery and otherwise to the same effect as the opinion required by Section 5(e) hereof.
Opinion of Special Tax Counsel. Supplemental Opinion of Special Tax Counsel.
Opinion of Special Tax Counsel. The City may deviate from the provisions of this Tax Certificate if furnished with an Opinion of Special Tax Counsel addressed to each of them to the effect that the proposed deviation will not adversely affect the exclusion of the interest portion of the Rental Payments on the Certificates from gross income for federal income tax purposes. The City will comply with any further or different instructions provided in an Opinion of Special Tax Counsel to the
Opinion of Special Tax Counsel for the Trust and the Company. At the Closing Time, the Company, the Trust and Underwriters shall have received an opinion, dated as of the Closing Time, of Ballxxx Xxxxx Xxxxxxx & Xngexxxxx, XXP, special tax counsel to the Trust and the Company, that (i) the Debt Securities will be classified for United States federal income tax purposes as indebtedness of the Company, (ii) the Trust will be classified for United States federal income tax purposes as a grantor trust and not as an association taxable as a corporation and (iii) although the discussion set forth in the Prospectus under the heading "Certain U.S. Federal Income Tax Consequences" does not purport to discuss all possible United States federal
Opinion of Special Tax Counsel for the Company and the Trust. The favorable opinion of Dickxxxxx Xxxgxx XXXC, special tax counsel to the Company and the Trust, in form and substance satisfactory to counsel for the Underwriters, dated such Date of Delivery, relating to the Option Securities and otherwise to the same effect as the opinion required by Section 5(c) hereof.
Opinion of Special Tax Counsel. Maryland Company will have received from special tax counsel an opinion, dated the Closing, to the effect that the transaction contemplated by this Agreement with respect to the contributed assets and liabilities is free from United States taxation pursuant to Section 721 of the Code.
Opinion of Special Tax Counsel. Texas Company will have received from special tax counsel an opinion, dated the Closing, to the effect that the transaction contemplated by this Agreement with respect to the contributed assets and liabilities is free from United States taxation pursuant to Section 721 of the Code.
