Opinion of Tax Counsel for Company. At the Closing Time, the Representatives shall have received the favorable opinion, dated the Closing Time, of Hunton & Xxxxxxxx LLP, tax counsel for the Company, together with signed or reproduced copies of such letter for each of the other Underwriters substantially in the form attached as Exhibit A-2 hereto.
Opinion of Tax Counsel for Company. The favorable opinion, dated such Date of Delivery, of Xxxxxx & Xxxxxx LLP, tax counsel for the Company, in form and substance reasonably satisfactory to the Representative, together with signed or reproduced copies of such letter for each of the other Underwriters, relating to the Option Securities to be purchased on such Date of Delivery and otherwise to the same effect as the opinion required by Section 6(c) hereof.
Opinion of Tax Counsel for Company. The favorable opinion of Dentons US LLP, tax counsel for the Company, in form and substance reasonably satisfactory to counsel for the Underwriters, dated such Date of Delivery, relating to the Option Securities to be purchased on such Date of Delivery and otherwise to the same effect as the opinion required by Section 5(c) hereof.
Opinion of Tax Counsel for Company. On each of the First Closing Date and each Option Closing Date the Representatives shall have received the opinion of Xxxxxxxx Chance US LLP, tax counsel for the Company, dated as of such date, in the form attached here to as Exhibit B and to such further effect as the Representatives shall reasonably request.
Opinion of Tax Counsel for Company. The Manager, the Forward Seller and the Forward Purchaser shall have received the favorable opinions of Xxxxxx & Xxxxxx L.L.P., required to be delivered pursuant to Section 7(q) on the date on which such delivery of such opinion is required pursuant to Section 7(q).
Opinion of Tax Counsel for Company. At Closing Time, the Representatives shall have received the favorable opinion, dated as of Closing Time, of Xxxxxxx Procter LLP, tax counsel for the Company, in form and substance reasonably satisfactory to counsel for the Underwriters, together with signed or reproduced copies of such letter for each of the other Underwriters that (i) commencing with the Company’s taxable year that began on January 1, 2003 and through the date hereof, the Company has been and is organized in conformity with the requirements for qualification as a REIT under the Code, and its method of operation through the date of the opinion has enabled, and will enable, it to meet the requirements for qualification and taxation as a REIT under the Code and (ii) the statements in the Prospectus under the caption “Federal Income Tax Considerations” as supplemented by the statements in the Prospectus Supplement under the caption “Supplemental United States Federal Income Tax Considerations” to the extent that such statements constitute matters of law or legal conclusions, have been reviewed by us and are correct in all material respects, as of the date of the opinion. In rendering such opinion, such counsel may rely upon factual representations and covenants of duly appointed officers of the Company and the Operating Partnership (including, without limitation, any such representations, covenants or statements made in certificates provided by such officers to counsel) and may make such assumptions as are customary with commercial practice.
Opinion of Tax Counsel for Company. At Closing Time, the Underwriters shall have received the favorable opinion, dated as of the Closing Time, of Xxxxxxxx & Worcester LLP, tax counsel for the Company, substantially in form and substance reasonably satisfactory to counsel for the Underwriters, together with signed or reproduced copies of such letter for each underwriter.
Opinion of Tax Counsel for Company. The favorable opinion of Xxxxxxx Procter LLP, tax counsel for the Company, in form and substance satisfactory to counsel for the Underwriters, dated such Date of Delivery, relating to the Option Securities to be purchased on such Date of Delivery and otherwise to the same effect as the opinion required by Section 5(c) hereof.
Opinion of Tax Counsel for Company. The opinion of Baker, Donelson, Bearman, Xxxxxxxx & Xxxxxxxxx, PC, tax counsel for the Company, in form and substance reasonably satisfactory to counsel for the Underwriters, dated such Date of Delivery, relating to the Option Securities to be purchased on such Date of Delivery and otherwise to the same effect as the opinion required by Section 5(c) hereof.
Opinion of Tax Counsel for Company. The favorable opinion of Skadden, Arps, Slate, Xxxxxxx & Xxxx LLP, tax counsel for the Company, in form and substance satisfactory to counsel for the Underwriters, dated such Date of Delivery, relating to the Option Securities to be purchased on such Date of Delivery and otherwise to the same effect as the opinion required by Section 5(d) hereof.
