Common use of Section 368 Opinion Clause in Contracts

Section 368 Opinion. CCIT III shall have received a written opinion of Transaction Opinion Counsel, or other tax counsel to CCIT III, dated as of the Closing Date, in form and substance reasonably acceptable to CCIT III, to the effect that, on the basis of facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify as a reorganization within the meaning of Section 368(a) of the Code, which opinion will be subject to customary exceptions, assumptions and qualifications. In rendering such opinion, such counsel may rely upon the tax representation letters described in Section 7.10.

Section 368 Opinion. CCIT III CCPT V shall have received a written opinion of Transaction Opinion Counsel, or other nationally recognized tax counsel to CCIT IIICCPT V, dated as of the Closing Date, in form and substance reasonably acceptable to CCIT IIICCPT V, to the effect that, on the basis of facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify as a reorganization within the meaning of Section 368(a) of the Code, which opinion will be subject to customary exceptions, assumptions and qualifications. In rendering such opinion, such counsel may rely upon the tax representation letters described in Section 7.10.

Section 368 Opinion. CCIT III II shall have received a written opinion of CCIT II Transaction Opinion Counsel, or other nationally recognized tax counsel to CCIT IIIII, dated as of the Closing Date, in form and substance reasonably acceptable to CCIT IIIII, to the effect that, on the basis of facts, representations and assumptions set forth or referred to in such opinion, the REIT Merger will qualify as a reorganization “reorganization” within the meaning of Section 368(a) of the Code, which opinion will be subject to customary exceptions, assumptions and qualifications. In rendering such opinion, such counsel may rely upon the tax representation letters described in Section 7.10.

Section 368 Opinion. CCIT III II shall have received a written opinion of Transaction Opinion Counsel, or other nationally recognized tax counsel to CCIT IIIII, dated as of the Closing Date, in form and substance reasonably acceptable to CCIT IIIII, to the effect that, on the basis of facts, representations and assumptions set forth or referred to in such opinion, the Merger will qualify as a reorganization within the meaning of Section 368(a) of the Code, which opinion will be subject to customary exceptions, assumptions and qualifications. In rendering such opinion, such counsel may rely upon the tax representation letters described in Section 7.10.