Premise of Opinion Sample Clauses

Premise of Opinion. Our opinion is limited to the federal income tax matters addressed herein, and no other opinions are rendered with respect to other federal tax matters or to any issues arising under the tax laws of any

Premise of Opinion. Our opinion is limited to the federal income tax matters addressed herein, and no other opinions are rendered with respect to other federal tax matters or to any issues arising under the tax laws of any foreign country, state, or locality. The opinion expressed herein is based on our interpretation of the Code, income tax regulations thereunder, court decisions, rulings and procedures issued by the Internal Revenue Service (the "Service") as of the date of this letter, and other authorities that we deemed relevant. Should there be any change, including any change having retroactive effect, in the Code, the regulations and rulings issued thereunder, judicial interpretations thereof, or in current understanding and interpretation of tax accounting practices, the opinion expressed herein would necessarily have to be reevaluated in light of any such changes. Additionally, should any of the representations or facts set forth herein prove to be either incomplete or inaccurate, as of the date hereof, our opinion may change. We have no responsibility to update our opinion for changes in facts, assumptions, representations, or technical authorities that arise after the date of our tax opinion. We have not considered any non-income tax or any state, local, foreign, or other income tax consequences, and therefore we express no opinion regarding the treatment that would be accorded the Distribution for such purposes. We also express no opinion on non-tax issues, such as corporate or securities law matters, including whether any tax disclosures included in documents made available to the shareholders of ITIG or the public are adequate within the requirements of the securities or corporate laws that govern the issuance of such documents and disclosures. Further, our opinion does not address the potential tax ramifications to the parties named herein or the stockholders of any transaction other than the Distribution and Contribution described herein. Our opinion does not address the tax consequences of the Distribution to a ITIG stockholder that has a special status, including insurance companies; tax-exempt entities; financial institutions or broker-dealers; foreign corporations; estates and trusts not subject to U.S. federal income tax on their income regardless of source; persons who are not citizens or residents of the United States; and persons who acquired their ITIG common stock as a result of the exercise of an employee stock option, pursuant to an employee stock...