Common use of Opinion of Tax Counsel Clause in Contracts

Opinion of Tax Counsel. The Company shall have received an opinion from Xxxxxx Xxxxxx Rosenman LLP, special counsel to the Company, dated the Closing Date, to the effect that, on the basis of the facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify as a “reorganization” within the meaning of Section 368(a) of the Code. In rendering its opinion, Xxxxxx Xxxxxx Xxxxxxxx LLP may require and rely upon representations contained in letters from each of HEOP and the Company.

Opinion of Tax Counsel. The Company shall have received an opinion from Xxxxxx Xxxxxx Rosenman McGuireWoods LLP, special counsel to the Company, dated as of the Closing Date, to the effect that, on the basis of the facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify as a “reorganization” within the meaning of Section 368(a) of the Code. In rendering its opinion, Xxxxxx Xxxxxx Xxxxxxxx McGuireWoods LLP may require and rely upon representations contained in letters or certificates from each of HEOP Parent and the Company, reasonably satisfactory in form and substance to such counsel.

Opinion of Tax Counsel. The Company shall have received an opinion from Xxxxxx Xxxxxx Rosenman of Xxxxxxxx & Xxxxxxxx LLP, special counsel to the Company, dated the Closing Date, to the effect that, that on the basis of the facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify be treated for federal income tax purposes as a “reorganization” reorganization within the meaning of Section 368(a) of the Internal Revenue Code. In rendering its opinion, Xxxxxx Xxxxxx Xxxxxxxx & Xxxxxxxx LLP may require and rely upon representations contained in letters from each of HEOP Parent and the Company.

Opinion of Tax Counsel. The Company shall have received an opinion from Xxxxxx Xxxxxx Rosenman Xxxxxxxxxx Xxxxxxxx & Xxxxxxxx LLP, special counsel to the Company, dated the Closing Date, to the effect that, on the basis of the facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify as a “reorganization” within the meaning of Section 368(a) of the Code. In rendering its opinion, Xxxxxx Xxxxxx Xxxxxxxxxx Xxxxxxxx & Xxxxxxxx LLP may require and rely upon representations contained in letters from each of HEOP Parent and the Company.

Opinion of Tax Counsel. The Company shall have received an opinion from Xxxxxx Xxxxxx Rosenman Bxxxx Xxxx LLP, special counsel to the Company, dated as of the Closing Date, to the effect that, on the basis of the facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify as a “reorganization” within the meaning of Section 368(a) of the Code. In rendering its opinion, Xxxxxx Xxxxxx Xxxxxxxx Bxxxx Xxxx LLP may require and rely upon representations contained in letters or certificates from each of HEOP Parent and the Company, reasonably satisfactory in form and substance to such counsel.

Opinion of Tax Counsel. The Company shall have received an opinion from Xxxxxx Xxxxxx Rosenman LLP, special counsel to the Company, dated the Closing Date, to the effect that, on the basis of the facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify as a “reorganization” within the meaning of Section 368(a) of the Code. In rendering its opinion, Xxxxxx Xxxxxx Xxxxxxxx LLP may require and rely upon representations contained in letters from each of HEOP Parent, Company and the CompanyBeach.

Opinion of Tax Counsel. The Company shall have received an opinion from Xxxxxx Xxxxxx Rosenman Hunton Xxxxxxx Xxxxx LLP, special counsel to the Company, dated the Closing Date, to the effect that, on the basis of the facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify as a “reorganization” within the meaning of Section 368(a) of the Code. In rendering its opinion, Xxxxxx Xxxxxx Xxxxxxxx Hunton Xxxxxxx Xxxxx LLP may require and rely upon representations contained in letters from each of HEOP HomeTrust and the Company.

Opinion of Tax Counsel. The Company shall will have received an opinion from Xxxxxx Xxxxxx Rosenman Xxxxxxxx & Xxxxxxxx LLP, special counsel to the Company, dated the Closing Date, to the effect that, on the basis of the facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify be treated for federal income tax purposes as a “reorganization” reorganization within the meaning of Section 368(a) of the Internal Revenue Code. In rendering its opinion, Xxxxxx Xxxxxx Xxxxxxxx & Xxxxxxxx LLP may require and rely upon representations contained in letters from each of HEOP Parent and the Company.

Opinion of Tax Counsel. The Company shall have received an opinion from Xxxxxx Xxxxxx Rosenman LLPHaynsworth Xxxxxxx Xxxx, P.A., special counsel to the Company, dated the Closing Date, to the effect that, on the basis of the facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify as a “reorganization” within the meaning of Section 368(a) of the Code. In rendering its opinion, Xxxxxx Xxxxxx Xxxxxxxx LLP Haynsworth Xxxxxxx Xxxx, P.A. may require and rely upon representations contained in letters from each of HEOP Parent, Company, and the Companyany subsidiary of either.

Opinion of Tax Counsel. The Company shall have received an opinion from of Xxxxxxx Xxxxxxxx Xxxxxx Xxxxxx Rosenman LLP, special counsel to the Company, dated as of the Closing Date, to the effect that, Date and based on the basis of the facts, representations and assumptions set forth or referred to described in such opinion, to the effect that the Merger will qualify be treated as a “reorganization” reorganization within the meaning of Section 368(a) of the Code. In rendering its such opinion, Xxxxxxx Xxxxxxxx Xxxxxx Xxxxxx Xxxxxxxx LLP may require will be entitled to receive and rely upon customary certificates and representations contained in letters from each of HEOP officers of the Company and the CompanyParent.

Opinion of Tax Counsel. The Company shall will have received an opinion from Xxxxxx Xxxxxx Rosenman Sxxxxxxx & Cxxxxxxx LLP, special counsel to the Company, dated the Closing Date, to the effect that, on the basis of the facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify be treated for federal income tax purposes as a “reorganization” reorganization within the meaning of Section 368(a) of the Internal Revenue Code. In rendering its opinion, Xxxxxx Xxxxxx Xxxxxxxx Sxxxxxxx & Cxxxxxxx LLP may require and rely upon representations contained in letters from each of HEOP Parent and the Company.