Common use of REIT Opinion Clause in Contracts

REIT Opinion. The Company shall have received a written opinion of Parent Tax Counsel, or other nationally recognized tax counsel to Parent, dated as of the Closing Date and substantially in the form set forth in Section 7.3(e) of the Parent Disclosure Schedule, to the effect that, commencing with Parent’s taxable year that ended on December 31, 2016, Parent has been organized and has operated in conformity with the requirements for qualification and taxation as a REIT under the Code and its current organization and its current and proposed method of operation will enable Parent to continue to meet the requirements for qualification and taxation as a REIT under the Code, which opinion will be subject to customary exceptions, assumptions and qualifications and based on customary representations contained in an officer’s certificate executed by Parent.

REIT Opinion. The Company shall have received a written opinion of Parent Tax CounselSidley Austin LLP, or other nationally recognized tax counsel to Parent, dated as of the Closing Date and substantially in the a form set forth in Section 7.3(e) customary for transactions of the Parent Disclosure Schedulethis nature, to the effect that, commencing with Parent’s short taxable year that beginning February 1, 2014 and ended on December 31, 20162014, Parent has been organized and has operated in conformity with the requirements for qualification and taxation as a REIT under the Code Code, and its current organization method of operation has enabled Parent to meet, through the Merger Effective Time and its current and proposed method of operation will enable Parent it to continue to meet meet, the requirements for qualification and taxation as a REIT under the Code, which opinion will be subject to customary exceptions, assumptions and qualifications and based on customary representations contained in an officer’s certificate executed by Parenta tax representation letter described in Section 7.10(b).

REIT Opinion. The Company Parent shall have received a written opinion of Parent Tax Counsel, or other nationally recognized tax counsel reasonably acceptable to Parentthe Company (“Parent REIT Counsel”) on which the Company shall be entitled to rely, dated as of the Closing Date and substantially in form and substance reasonably satisfactory to the form set forth in Section 7.3(e) of the Parent Disclosure ScheduleCompany, to the effect that, commencing with Parent’s taxable year that ended on December 31, 20161999, Parent has been organized and has operated in conformity with the requirements for qualification and taxation as a REIT under the Code Code, and its current organization and its current and proposed method of operation will enable Parent to continue to meet the requirements for qualification and taxation as a REIT under the Code, which opinion will be subject to customary exceptions, assumptions and qualifications and based on customary representations contained in an officer’s certificate executed by ParentParent and provided pursuant to Section 6.2(a).