OTHER TAX OPINION. EQR shall have received an opinion dated the Closing Date from counsel to EQR, based upon certificates and letters, which letters and certificates are substantially in the form set forth in Exhibit "L" hereto and dated the Closing Date, to the effect that the Merger will qualify as a reorganization under the provisions of Section 368(a) of the Code.
OTHER TAX OPINION. Wellsford shall have received an opinion dated the Closing Date from counsel to Wellsford, based upon certificates and letters, which letters and certificates are substantially in the form set forth in Exhibit "N" hereto and dated the Closing Date, to the effect that the Merger will qualify as a reorganization under the provisions of Section 368(a) of the Code.
OTHER TAX OPINION. TriNet shall have received an opinion dated as of the Closing Date from Xxxx Xxxxx, Rifkind, Xxxxxxx & Xxxxxxxx in form reasonably satisfactory to Starwood (subject to customary assumptions and qualifications, and based on customary representations) to the effect that the Merger will qualify as a tax-free reorganization under Section 368(a) of the Code.
OTHER TAX OPINION. The Company shall have received either (i) a ruling from the IRS or (ii) an opinion dated as of the Closing Date from Counsel to the Company, to the effect that the Merger should qualify as a reorganization under the provisions of Section 368(a) of the Code and that the Surviving Company will constitute a "qualified REIT subsidiary" under Section 856(i). 6.3.6
OTHER TAX OPINION. Camden shall have received an opinion dated as of the Closing Date from Counsel to Camden, based upon certificates and letters, to the effect that the Merger will qualify as a reorganization under the provisions of Section 368(a) of the Code.
OTHER TAX OPINION. The Company shall have received an opinion dated as of the Closing Date from Counsel to the Company, based upon certificates and letters, which letters and certificates are substantially in the form set forth in EXHIBIT F hereto and dated the Closing Date, to the effect that the Merger will qualify as a reorganization under the provisions of Section 368(a) of the Code.
OTHER TAX OPINION. 6.2.6 Consents.................................................... SECTION 6.3 Conditions to Obligations of the Company.................... 6.3.1
OTHER TAX OPINION. 6.3.6 Consents.................................................... ARTICLE VII -
OTHER TAX OPINION. Duke shall have received an opinion dated as of ----------------- the Closing Date from Xxxxxx & Xxxxx LLP to the effect that the REIT Merger will qualify as a tax-free reorganization Duke under Section 368(a) of the Code.
OTHER TAX OPINION. Weeks shall have received an opinion dated as of ----------------- the Closing Date from King & Spalding (subject to customary exceptions, assumptions and qualifications, and based on customary representations) to the effect that the REIT Merger will qualify as a tax-free reorganization under Section 368(a) of the Code.
