Common use of Tax Opinions Relating to the Merger Clause in Contracts

Tax Opinions Relating to the Merger. CenterState and HCBF, respectively, shall have received opinions from Axxxxx & Bird LLP and Skadden, Arps, Slate, Mxxxxxx & Fxxx LLP, respectively, each dated as of the Closing Date, in substance and form reasonably satisfactory to CenterState and HCBF, respectively, to the effect that, on the basis of the facts, representations and assumptions set forth in such opinion, the Merger will be treated for federal income tax purposes as a “reorganization” within the meaning of Section 368(a) of the Code. In rendering their opinions, Axxxxx & Bird LLP and Skadden, Arps, Slate, Mxxxxxx & Fxxx LLP may require and rely upon representations as to certain factual matters contained in certificates of officers of each of CenterState and HCBF, in form and substance reasonably acceptable to such counsel.

Tax Opinions Relating to the Merger. CenterState FBMS and HCBFSSNF, respectively, shall have received opinions from Axxxxx & Bird LLP and SkaddenSilver, Arps, Slate, Mxxxxxx Fxxxxxxx Taff & Fxxx Txxxxxx LLP, respectively, each dated as of the Closing Date, in substance and form reasonably satisfactory to CenterState FBMS and HCBFSSNF, respectively, to the effect that, on the basis of the facts, representations and assumptions set forth in such opinionopinions, the Merger will be treated for federal income tax purposes as a “reorganization” within the meaning of Section 368(a) of the Code. In rendering their opinions, Axxxxx & Bird LLP and SkaddenSilver, Arps, Slate, Mxxxxxx Fxxxxxxx Txxx & Fxxx Txxxxxx LLP may require and rely upon representations as to certain factual matters contained in certificates of officers of each of CenterState FBMS and HCBFSSNF, in form and substance reasonably acceptable to such counsel.

Tax Opinions Relating to the Merger. CenterState BFC and HCBFHTB, respectively, shall have received opinions from Axxxxx & Bird LLP and SkaddenRxxxxxxx Xxxxxxx Van Deuren, Arps, Slate, Mxxxxxx & Fxxx LLPS.C., respectively, each dated as of the Closing Date, in substance and form reasonably satisfactory to CenterState BFC and HCBFHTB, respectively, to the effect that, on the basis of the facts, representations and assumptions set forth in such opinionopinions, the Merger will be treated for federal income tax purposes as a “reorganization” within the meaning of Section 368(a) of the Code. In rendering their opinions, Axxxxx & Bird LLP and SkaddenRxxxxxxx Xxxxxxx Van Deuren, Arps, Slate, Mxxxxxx & Fxxx LLP S.C. may require and rely upon representations as to certain factual matters contained in certificates of officers of each of CenterState BFC and HCBFHTB, in form and substance reasonably acceptable to such counsel.

Tax Opinions Relating to the Merger. CenterState CBAN and HCBFLBC, respectively, shall have received opinions from Axxxxx Xxxxxx & Bird LLP and Skadden, Arps, Slate, Mxxxxxx & Fxxx Xxxxx-Xxxxx-Xxxxxxx-Xxxxxxx-LLP, respectively, each dated as of the Closing Date, in substance and form reasonably satisfactory to CenterState CBAN and HCBFLBC, respectively, to the effect that, on the basis of the facts, representations and assumptions set forth in such opinionopinions, the Merger will be treated for federal income tax purposes as a “reorganization” within the meaning of Section 368(a) of the Code. In rendering their opinions, Axxxxx Xxxxxx & Bird LLP and Skadden, Arps, Slate, Mxxxxxx & Fxxx Xxxxx-Xxxxx-Xxxxxxx-Xxxxxxx-LLP may require and rely upon representations as to certain factual matters contained in certificates of officers of each of CenterState CBAN and HCBFLBC, in form and substance reasonably acceptable to such counsel.

Tax Opinions Relating to the Merger. CenterState FBMS and HCBFSSNF, respectively, shall have received opinions from Axxxxx Xxxxxx & Bird LLP and SkaddenSilver, Arps, Slate, Mxxxxxx Xxxxxxxx Taff & Fxxx Xxxxxxx LLP, respectively, each dated as of the Closing Date, in substance and form reasonably satisfactory to CenterState FBMS and HCBFSSNF, respectively, to the effect that, on the basis of the facts, representations and assumptions set forth in such opinionopinions, the Merger will be treated for federal income tax purposes as a “"reorganization” " within the meaning of Section 368(a) of the Code. In rendering their opinions, Axxxxx Xxxxxx & Bird LLP and SkaddenSilver, Arps, Slate, Mxxxxxx Xxxxxxxx Xxxx & Fxxx Xxxxxxx LLP may require and rely upon representations as to certain factual matters contained in certificates of officers of each of CenterState FBMS and HCBFSSNF, in form and substance reasonably acceptable to such counsel.

Tax Opinions Relating to the Merger. CenterState FBMS and HCBFFPB, respectively, shall have received opinions from Axxxxx & Bird LLP and SkaddenSilver, Arps, Slate, Mxxxxxx Fxxxxxxx Txxx & Fxxx Txxxxxx LLP, respectively, each dated as of the Closing Date, in substance and form reasonably satisfactory to CenterState FBMS and HCBFFPB, respectively, to the effect that, on the basis of the facts, representations and assumptions set forth in such opinionopinions, the Merger will be treated for federal income tax purposes as a “reorganization” within the meaning of Section 368(a) of the Code. In rendering their opinions, Axxxxx & Bird LLP and SkaddenSilver, Arps, Slate, Mxxxxxx Fxxxxxxx Txxx & Fxxx Txxxxxx LLP may require and rely upon representations as to certain factual matters contained in certificates of officers of each of CenterState FBMS and HCBFFPB, in form and substance reasonably acceptable to such counsel.

Tax Opinions Relating to the Merger. CenterState CBAN and HCBFSCSG, respectively, shall have received opinions from Axxxxx Xxxxxxxx, Xxx, Xxxxxxxx & Ford, LLP and Xxxxxx & Bird LLP and Skadden, Arps, Slate, Mxxxxxx & Fxxx LLP, respectively, each dated as of the Closing Date, in substance and form reasonably satisfactory to CenterState CBAN and HCBFSCSG, respectively, to the effect that, on the basis of the facts, representations and assumptions set forth in such opinionopinions, the Merger will be treated for federal income tax purposes as a “reorganization” within the meaning of Section 368(a) of the Code. In rendering their opinions, Axxxxx Xxxxxxxx, Xxx, Xxxxxxxx & Ford, LLP and Xxxxxx & Bird LLP and Skadden, Arps, Slate, Mxxxxxx & Fxxx LLP may require and rely upon representations as to certain factual matters contained in certificates of officers of each of CenterState CBAN and HCBFSCSG, in form and substance reasonably acceptable to such counsel.