Common use of Opinion of Tax Counsel for Company and the Operating Partnership Clause in Contracts

Opinion of Tax Counsel for Company and the Operating Partnership. The favorable opinion of DLA Piper LLP (US), tax counsel for the Company and the Operating Partnership, in form and substance satisfactory reasonably 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.