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 Xxxxxx & Bird LLP and Skadden, Arps, Slate, Xxxxxxx & Xxxx 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, Xxxxxx & Bird LLP and Skadden, Arps, Slate, Xxxxxxx & Xxxx 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 and HCBFCharter, respectively, shall have received opinions from Xxxxxx Xxxxxxx Xxxxx & Xxxxxxxxxxx LLP and Xxxxxx & Bird LLP and Skadden, Arps, Slate, Xxxxxxx & Xxxx LLP, respectively, each dated as of the Closing Date, in substance and form reasonably satisfactory to CenterState and HCBFCharter, respectively, to the effect that, based on the terms of this Agreement and 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, Xxxxxx Xxxxxxx Xxxxx & Xxxxxxxxxxx LLP and Xxxxxx & Bird LLP and Skadden, Arps, Slate, Xxxxxxx & Xxxx LLP may require and rely upon representations as to certain factual matters contained in certificates of officers of each of CenterState and HCBFCharter, in form and substance reasonably acceptable to such counsel.

Tax Opinions Relating to the Merger. CenterState and HCBF, respectively, shall have received opinions from Xxxxxx Axxxxx & Bird LLP and Skadden, Arps, Slate, Xxxxxxx Mxxxxxx & Xxxx 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, Xxxxxx Axxxxx & Bird LLP and Skadden, Arps, Slate, Xxxxxxx Mxxxxxx & Xxxx 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.