Common use of Opinion Relating to the Merger Clause in Contracts

Opinion Relating to the Merger. CPA16 and Merger Sub shall have received an opinion from Xxxxxxxx Chance US LLP, dated as of the Closing Date, to the effect that (i) the Merger will qualify as a reorganization within the meaning of Section 368(a) of the Code and (ii) each of CPA14 and Merger Sub will be parties to such reorganization within the meaning of Section 368(b) of the Code. For purposes of the foregoing opinion, which shall be in a form customary for transactions of this nature, Xxxxxxxx Chance US LLP shall be entitled to rely upon customary assumptions and representations of XXX00, XXX00 and Merger Sub.

Opinion Relating to the Merger. CPA16 and Merger Sub CPA14 shall have received an opinion from Xxxxxxxx Chance US of Xxxxxxxxx Xxxxxxx, LLP, dated as of the Closing Date, to the effect that (i) the Merger will qualify as a reorganization within the meaning of Section 368(a) of the Code and (ii) each of CPA14 and Merger Sub will be parties to such reorganization within the meaning of Section 368(b) of the Code. For purposes of the foregoing opinion, which shall be in a form customary for transactions of this nature, Xxxxxxxx Chance US Xxxxxxxxx Traurig, LLP shall be entitled to rely upon customary assumptions and representations of XXX00, XXX00 and Merger Sub.