Opinion of Tax Counsel for the Company. At the Closing Time, the Representatives shall have received the opinion, dated as of the Closing Time, of Baker, Donelson, Bearman, Xxxxxxxx & Xxxxxxxxx, PC, tax counsel for the Transaction Entities, 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, substantially to the effect set forth in Exhibit A-3 hereto.
Opinion of Tax Counsel for the Company. On each of the First Closing Date and each Option Closing Date the Representatives shall have received the opinion of Bass, Xxxxx & Xxxx PLC, counsel for the Company with respect to certain federal income tax matters, dated as of such date, in the form attached hereto as Exhibit E.
Opinion of Tax Counsel for the Company. Baker, Donelson, Bearman, Xxxxxxxx & Xxxxxxxxx, P.C., tax counsel of the Company, shall have furnished to the Representatives, at the request of the Company, their written opinion, dated the Closing Date or the Additional Closing Date, as the case may be, and addressed to the Underwriters, in form and substance reasonably satisfactory to the Representatives, substantially in the form set forth in Annex C hereto.
Opinion of Tax Counsel for the Company. Xxxxx Xxxx & Xxxxxxxx LLP, tax counsel for the Company, shall have furnished to the Underwriters, at the request of the Company, their written opinion, dated the Closing Date, and addressed to the Underwriters, in form and substance reasonably satisfactory to the Underwriters.
Opinion of Tax Counsel for the Company. On each of the First Closing Date and each Option Closing Date, the Representatives shall have received the opinion of Skadden, Arps, Slate, Xxxxxxx & Xxxx LLP, U.S. counsel for the Company with respect to tax matters, dated as of such date, substantially in the form attached hereto attached hereto as Exhibit D and to such further effect as the Representatives shall reasonably request.
Opinion of Tax Counsel for the Company. Gxxxxxx Procter LLP, tax counsel for the Company, shall have furnished to the Representatives, at the request of the Company, their written opinion, dated the Closing Date and addressed to the Underwriters, to the effect that, subject to the assumptions and qualifications therein commencing with the taxable year ending December 31, 1994, the form of organization of the Company and its operations are such as to enable the Company to qualify as a “real estate investment trust” under the applicable provisions of the Code.
Opinion of Tax Counsel for the Company. If requested by the Representatives, the opinion of Hunton & Xxxxxxxx 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 the Company. Xxxxx Xxxxx LLP, special tax counsel for the Company, shall have furnished to the Representatives, at the request of the Company, their written opinion, dated the Closing Date or the Additional Closing Date, as the case may be, and addressed to the Underwriters, in form and substance reasonably satisfactory to the Representatives, to the effect set forth in Annex C-[6] hereto.
Opinion of Tax Counsel for the Company. The Representative shall have received an opinion, dated such Closing Date, of Xxxxxx, tax counsel for the Company, in the form attached as Exhibit A-2 hereto.
Opinion of Tax Counsel for the Company. The favorable opinion of Skadden, Arps, Slate, Xxxxxxx & Xxxx LLP, tax counsel for the Company, substantially in the form of Exhibit __ attached hereto.
