Section 368 Opinion. CMFT shall have received a written opinion of Transaction Opinion Counsel, or other nationally recognized tax counsel to CMFT, dated as of the Closing Date, in form and substance reasonably acceptable to CMFT, 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.
Appears in 4 contracts
Samples: Agreement and Plan of Merger (Cim Income Nav, Inc.), Agreement and Plan of Merger (Cole Office & Industrial REIT (CCIT III), Inc.), Agreement and Plan of Merger (Cole Credit Property Trust V, Inc.)
Section 368 Opinion. CMFT shall have received a written opinion of Transaction Opinion Counsel, or other nationally recognized tax counsel to CMFT, dated as of the Closing Date, in form and substance reasonably acceptable to CMFT, 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.
Appears in 2 contracts
Samples: Agreement and Plan of Merger (Cim Real Estate Finance Trust, Inc.), Agreement and Plan of Merger (Cole Office & Industrial REIT (CCIT III), Inc.)
