OTHER TAX OPINION. TriNet shall have received an opinion dated as of the Closing Date from Xxxx Xxxxx, Rifkind, Xxxxxxx & Xxxxxxxx in form reasonably satisfactory to Starwood (subject to customary assumptions and qualifications, and based on customary representations) to the effect that the Merger will qualify as a tax-free reorganization under Section 368(a) of the Code.
Appears in 2 contracts
Samples: Agreement and Plan of Merger (Trinet Corporate Realty Trust Inc), Agreement and Plan of Merger (Starwood Financial Trust)
OTHER TAX OPINION. TriNet Starwood shall have received an opinion dated as of the Closing Date from Xxxx Xxxxx, Rifkind, Xxxxxxx Xxxxxx & Xxxxxxxx Xxxxx LLP in form reasonably satisfactory to Starwood TriNet (subject to customary assumptions and qualifications, and based on customary representations) to the effect that the Merger will qualify as a tax-free reorganization under Section 368(a) of the Code.
Appears in 2 contracts
Samples: Agreement and Plan of Merger (Trinet Corporate Realty Trust Inc), Agreement and Plan of Merger (Starwood Financial Trust)
