Common use of REIT Qualification Opinion Clause in Contracts

REIT Qualification Opinion. Parent shall have received a written tax opinion of Xxxxxxxx Xxxxx (or such other nationally recognized REIT counsel as may be reasonably acceptable to Parent and the Company), substantially in the form of Exhibit D to this Agreement, dated as of the Closing Date, to the effect that, beginning with its taxable year ended December 31, 1995 and ending with its taxable year that ends with the Closing Date, the Company has been organized and operated in conformity with the requirements for qualification and taxation as a REIT under the Code (which opinion shall be based upon the representation letters described in Section 7.15(a)(ii) and subject to customary exceptions, assumptions and qualifications).

REIT Qualification Opinion. Parent shall have received a written tax opinion of Xxxxxxxx Xxxxx Company Counsel (or such other nationally recognized REIT counsel as may be reasonably acceptable to Parent and the Company), substantially in the form of Exhibit D A to this Agreement, dated as of the Closing Date, to the effect that, beginning with its taxable year ended December 31, 1995 2009 and ending with its taxable year that ends with immediately prior to the Closing DateCompany Merger Effective Time, the Company has been organized and operated in conformity with the requirements for qualification and taxation as a REIT under the Code (which opinion shall be based upon the representation letters described in Section 7.15(a)(ii) and subject to customary exceptions, assumptions and qualifications).

REIT Qualification Opinion. Parent shall have received a written tax opinion of Xxxxxxxx Xxxxx Cozen X’Xxxxxx P.C. (or such other nationally recognized REIT counsel as may be reasonably acceptable to Parent and the Company), substantially in the form of Exhibit D A to this Agreement, dated as of the Closing Date, to the effect that, beginning with its taxable year ended December 31, 1995 1997 and ending with its taxable year that ends with at the Closing Datemoment in time immediately prior to the Topco Merger Effective Time, the Company has been organized and operated in conformity with the requirements for qualification and taxation as a REIT under the Code (which opinion shall be based upon the representation letters described in Section 7.15(a)(ii) and subject to customary exceptions, assumptions and qualifications).

REIT Qualification Opinion. Parent shall have received a written tax opinion of Xxxxxxxx Xxxxx Cozen O’Xxxxxx P.C. (or such other nationally recognized REIT counsel as may be reasonably acceptable to Parent and the Company), substantially in the form of Exhibit D A to this Agreement, dated as of the Closing Date, to the effect that, beginning with its taxable year ended December 31, 1995 1997 and ending with its taxable year that ends with at the Closing Datemoment in time immediately prior to the Topco Merger Effective Time, the Company has been organized and operated in conformity with the requirements for qualification and taxation as a REIT under the Code (which opinion shall be based upon the representation letters described in Section 7.15(a)(ii) and subject to customary exceptions, assumptions and qualifications).

REIT Qualification Opinion. Parent shall have received a written tax opinion of Xxxxxxxx Xxxxx Xxxxxx & Bird LLP (or such other nationally recognized REIT counsel as may be reasonably acceptable to Parent and the Company), substantially in the form of Exhibit D A to this Agreement, dated as of the Closing Date, to the effect that, beginning with its taxable year ended December 31, 1995 1999 and ending with its taxable year that ends with the Closing DateCompany Merger, the Company has been organized and operated in conformity with the requirements for qualification and taxation as a REIT under the Code (which opinion shall be based upon the representation letters described in Section 7.15(a)(ii) and subject to customary exceptions, assumptions and qualifications).

REIT Qualification Opinion. Parent shall have received a written tax opinion of Xxxxxxxx Xxxxx Axxxxx & Bird LLP (or such other nationally recognized REIT counsel as may be reasonably acceptable to Parent and the Company), substantially in the form of Exhibit D A to this Agreement, dated as of the Closing Date, to the effect that, beginning with its taxable year ended December 31, 1995 1999 and ending with its taxable year that ends with the Closing DateCompany Merger, the Company has been organized and operated in conformity with the requirements for qualification and taxation as a REIT under the Code (which opinion shall be based upon the representation letters described in Section 7.15(a)(ii) and subject to customary exceptions, assumptions and qualifications).