OTHER TAX OPINION. Wellsford shall have received an opinion dated the Closing Date from counsel to Wellsford, based upon certificates and letters, which letters and certificates are substantially in the form set forth in Exhibit "N" hereto and dated the Closing Date, to the effect that the Merger will qualify as a reorganization under the provisions of Section 368(a) of the Code.
Appears in 4 contracts
Samples: Tax Sharing Agreement (Equity Residential Properties Trust), Agreement and Plan of Merger (Equity Residential Properties Trust), Agreement and Plan of Merger (Wellsford Residential Property Trust)
