REIT Qualification Opinion. The Buyer shall have furnished the Company with an opinion of Hunton & Xxxxxxxx LLP, dated as of the Closing Date, to the effect that (a) commencing with its taxable year ended December 31, 2004, and for each taxable year ended through December 31, 2006, the Buyer has been organized and operated in conformity with the requirements for qualification and taxation as a REIT and (b) the Buyer’s organization and current and proposed method of operation (including the consummation of the transactions contemplated hereby and after the consummation thereof) will enable it to continue to meet the requirements for qualification and taxation as a REIT for its taxable year ending December 31, 2007 and in the future.
Appears in 2 contracts
Samples: Note Purchase Agreement (Deerfield Triarc Capital Corp), Agreement and Plan of Merger (Triarc Companies Inc)
REIT Qualification Opinion. The Buyer shall have furnished the Company with an opinion of Hunton & Xxxxxxxx Williams LLP, dated as of the Closing Date, to the effect that (a) commencing xxxxxxxxng with its taxable year ended December 31, 2004, and for each taxable year ended through December 31, 2006, the Buyer has been organized and operated in conformity with the requirements for qualification and taxation as a REIT and (b) the Buyer’s 's organization and current and proposed method of operation (including the consummation of the transactions contemplated hereby and after the consummation thereof) will enable it to continue to meet the requirements for qualification and taxation as a REIT for its taxable year ending December 31, 2007 and in the future.
Appears in 1 contract
Samples: Agreement and Plan of Merger (Triarc Companies Inc)
REIT Qualification Opinion. The Buyer shall have furnished the Company with an opinion of Hunton & Xxxxxxxx Williams LLP, dated as of the Closing Date, to the effect that (a) commencing coxxxxxxxx with its taxable year ended December 31, 2004, and for each taxable year ended through December 31, 2006, the Buyer has been organized and operated in conformity with the requirements for qualification and taxation as a REIT and (b) the Buyer’s 's organization and current and proposed method of operation (including the consummation of the transactions contemplated hereby and after the consummation thereof) will enable it to continue to meet the requirements for qualification and taxation as a REIT for its taxable year ending December 31, 2007 and in the future.
Appears in 1 contract
Samples: Agreement and Plan of Merger (Deerfield Triarc Capital Corp)
