Certain Federal Income Tax Considerations and "Federal Income Tax Considerations," to the extent that it constitutes matters of law or legal conclusions, has been reviewed by them and is correct in all material respects.
Certain Federal Income Tax Considerations and "Notice to Investors,"](12) insofar as such statements constitute matters of law, summaries of legal matters, documents or legal conclusions, have been reviewed by such counsel, fairly summarize, in all material respects, the matters referred to therein and do not omit a material fact necessary to make the statements contained therein not misleading.
Certain Federal Income Tax Considerations. Description of Securities" and (ii) in the Registration Statement in Item 24 insofar as such statements constitute a summary of statutes, legal and governmental proceedings, contracts and other documents, are accurate summaries in all material respects and fairly present the information called for with respect to such matters. In expressing the foregoing opinion, as to matters of fact relevant to conclusions of law, counsel may rely, to the extent that they deem proper, upon certificates of public officials and of the officers of the Company, provided that copies of such officers' certificates are attached to the opinion. In addition to the matters set forth above, such counsel shall have furnished to the Underwriter a written statement to the effect that such counsel has acted as counsel to the Company on a regular basis and has acted as counsel in connection with the preparation of the Registration Statement, Preliminary Prospectus or Prospectus, and based on the foregoing, no facts have come to the attention of such counsel which causes them to believe that the Registration Statement, Preliminary Prospectus or Prospectus (other than the financial statements and supporting financial and statistical data included or incorporated therein, as to which such counsel need express no opinion as of First Closing Date or Second Closing Date, as the case may be) contains an untrue statement of a material fact or omits to state a material fact required to be stated therein or necessary to make the statements therein, in light of the circumstances in which they were made, not misleading; provided, however, that such written statement of counsel does not require any statement concerning statements in, or omissions from, the Registration Statement, Preliminary Prospectus or Prospectus, or any amendment thereof or supplement thereto, which are based upon and conform to written information furnished to the Company by the Underwriter specifically for use in the preparation of the Registration Statement, Preliminary Prospectus or the Prospectus, or any such amendment or supplement. The foregoing statement may be qualified by a statement to the effect that such counsel does not assume responsibility for the accuracy, completeness or fairness of the statements in the Registration Statement or the Prospectus, except for the statements made in the Prospectus under the captions "Description of Capital Stock" and "Certain Federal Income Tax Considerations."
Examples of Certain Federal Income Tax Considerations in a sentence
We hereby consent to the filing with the Securities and Exchange Commission of this letter as an exhibit to the Registration Statement and the reference to us under the heading "Certain Federal Income Tax Considerations".
We hereby consent to the filing of this opinion as an exhibit to the Registration Statement and to the reference to this firm and the summarization of this opinion under the section titled "Certain Federal Income Tax Considerations" in the Registration Statement.
We hereby confirm our opinions set forth in the Registration Statement under the caption "Certain Federal Income Tax Considerations." Furthermore, it is our opinion that the discussion under the caption "Certain Federal Income Tax Considerations," to the extent it discusses matters of law or legal conclusions, is correct in all material respects.
We consent to the filing of this opinion as an Exhibit to the Registration Statement and to the reference to Giancarlo & Gnazzo, A Professional Corporation under the caption "Certain Federal Income Tax Considerations" in the Prospectus included in the Registration Statement.
We consent to the reference to our firm under the caption "Certain Federal Income Tax Considerations" included in the Registration Statement and to the filing of this opinion as an exhibit to the Registration Statement.
More Definitions of Certain Federal Income Tax Considerations
Certain Federal Income Tax Considerations and "Exchange Offer; Registration Rights," to the extent that it constitutes summaries of legal matters or legal proceedings, or legal conclusions, has been reviewed by us and fairly summarizes the matters described therein.3
Certain Federal Income Tax Considerations or any similar caption or captions, if applicable, and in the Registration Statement under Item 15, to the extent that it constitutes matters of law, summaries of legal matters, the Company's charter and bylaws or legal proceedings, or legal conclusions, has been reviewed by such counsel and is correct in all material respects; and, if applicable, the opinion of the firm set forth under "Certain Federal Income Tax Considerations" or any similar caption, if applicable, is confirmed.
Certain Federal Income Tax Considerations and “Federal Income Tax Consequences”, and under the caption “Plan of Distribution”, insofar as they purport to describe the provisions of the laws and documents referred to therein, are accurate, complete and fair.
Certain Federal Income Tax Considerations and "Notice to Investors" in the Offering Memorandum insofar as such statements constitute a general summary of matters of United States law or of documents referred to therein are true and accurate in all material respects and fairly summarize the matters referred to therein;
Certain Federal Income Tax Considerations and "Plan of Distribution," insofar as they purport to describe the provisions of the laws and documents referred to therein, are correct in all material respects;
Certain Federal Income Tax Considerations and "[!]" and in the Registration Statement under Item 15, to the extent that it constitutes matters of law, summaries of legal matters, the Company's charter and bylaws or legal proceedings, or legal conclusions, has been reviewed by us and is correct in all material respects; and the opinion of such firm set forth under "Certain Federal Income Tax Considerations" is confirmed.
Certain Federal Income Tax Considerations. Description of Capital Stock," "Share Eligible for Future Sale," and (ii) in the Registration Statement in Item 14 insofar as such statements constitute a summary of statutes, legal and governmental proceedings, contracts and other documents, are accurate summaries in all material respects and fairly present the information called for with respect to such matters.