Common use of Section 368 Opinion Clause in Contracts

Section 368 Opinion. REIT II shall have received a written opinion of ▇▇▇▇▇▇ & ▇▇▇▇▇▇ L.L.P., or other counsel to REIT II reasonably satisfactory to REIT I, dated as of the Closing Date and in form and substance reasonably satisfactory to REIT II, 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, ▇▇▇▇▇▇ & ▇▇▇▇▇▇ L.L.P. may rely upon the tax representation letters described in Section 7.12.

Section 368 Opinion. REIT II I shall have received a written opinion of ▇V▇▇▇▇▇ & ▇E▇▇▇▇▇ L.L.P., or other counsel to REIT II I reasonably satisfactory to REIT III, dated as of the Closing Date and in form and substance reasonably satisfactory to REIT III, 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 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, ▇V▇▇▇▇▇ & ▇E▇▇▇▇▇ L.L.P. may rely upon the tax representation letters described in Section 7.127.13.

Section 368 Opinion. REIT II I shall have received a written opinion of ▇▇▇▇▇▇ & ▇▇▇▇▇▇ L.L.P.LLP, or other counsel to REIT II I reasonably satisfactory to REIT III, dated as of the Closing Date and in form and substance reasonably satisfactory to REIT 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, ▇▇▇▇▇▇ & ▇▇▇▇▇▇ L.L.P. LLP may rely upon the tax representation letters described in Section 7.12.

Section 368 Opinion. REIT II I shall have received a written opinion of ▇▇▇▇▇▇ & ▇▇▇▇▇▇ L.L.P.DLA Piper, tax counsel to REIT I, or other tax counsel to REIT II I reasonably satisfactory to REIT III, dated as of the Closing Date and in form and substance reasonably satisfactory to REIT 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, ▇▇▇▇▇▇ & ▇▇▇▇▇▇ L.L.P. DLA Piper may rely upon the tax representation letters described in Section 7.12.

Section 368 Opinion. REIT II shall have received a written opinion of ▇▇▇▇▇▇, ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇ L.L.P.▇, LLP, or other tax counsel to REIT II reasonably satisfactory to REIT I, dated as of the Closing Date and in form and substance reasonably satisfactory to REIT II, 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, ▇▇▇▇▇▇, ▇▇▇▇▇▇▇ & ▇▇▇▇▇▇ L.L.P. ▇, LLP, may rely upon the tax representation letters described in Section 7.12.