REIT Opinion. Each Purchaser shall have received an opinion of Xxxxxx & Xxxxxx LLP, dated as of the Closing Date, substantially in the form attached hereto as Exhibit J, that the Company (x) for all taxable years commencing with the taxable year ended December 31, 2005 through December 31, 2009, has been subject to taxation as a REIT and (y) has operated since January 1, 2010 to the Closing Date in a manner consistent with the requirements for qualification and taxation as a REIT.
Appears in 11 contracts
Samples: Non Control Agreement (Pershing Square Capital Management, L.P.), Stock Purchase Agreement (General Growth Properties, Inc.), Stock Purchase Agreement (General Growth Properties, Inc.)
REIT Opinion. Each Purchaser shall have received an opinion of Xxxxxx & Xxxxxx LLP, dated as of the Closing Date, substantially in the form attached hereto as Exhibit J, that the Company (x) for all taxable years commencing with the taxable year ended December 31, 2005 through December 31, 2009, has been subject to taxation as a REIT and (y) has operated since January 1, 2010 to the Closing Date in a manner consistent with the requirements for qualification and taxation as a REIT.
Appears in 5 contracts
Samples: Cornerstone Investment Agreement, Escrow Agreement (General Growth Properties Inc), Cornerstone Investment Agreement (General Growth Properties Inc)
REIT Opinion. Each Purchaser shall have received an opinion of Xxxxxx & Xxxxxx LLP, dated as of the Closing Date, substantially in the form attached hereto as Exhibit JA, that the Company (x) for all taxable years commencing with the taxable year ended December 31, 2005 through December 31, 2009, has been subject to taxation as a REIT and (y) has operated since January 1, 2010 to the Closing Date in a manner consistent with the requirements for qualification and taxation as a REIT.
Appears in 1 contract
Samples: Stock Purchase Agreement (General Growth Properties Inc)
