Common use of Opinion Relating to REIT Qualification Clause in Contracts

Opinion Relating to REIT Qualification. Company shall have received the written opinion of ▇▇▇▇▇ & ▇▇▇▇▇▇▇ LLP (or other counsel reasonably satisfactory to Company), dated as of the Closing Date in substantially the form attached hereto as Exhibit E, to the effect that for all taxable periods commencing with its taxable year ended December 31, 2019 and through the Closing Date, Parent has been organized and operated in conformity with the requirements for qualification and taxation as a REIT under the Code, and that its proposed method of organization and operation will permit Parent to continue to qualify for taxation as a REIT under the Code for its taxable year which includes the Closing Date (which opinion shall be based upon the representation letter described in Section 7.13(a) and Section 7.13(b) and shall be subject to customary assumptions, limitations and qualifications).

Opinion Relating to REIT Qualification. Company shall have received the written opinion of ▇▇▇▇▇ & ▇▇▇▇▇▇▇ Lovells US LLP (or other counsel reasonably satisfactory to Company), dated as of the Closing Date in substantially the form attached hereto as Exhibit ED, to the effect that for all taxable periods commencing with its taxable year ended December 31, 2019 and through the Closing Date2004, Parent has been organized and operated in conformity with the requirements for qualification and taxation as a REIT under the Code, and that its proposed method of past, current and intended future organization and operation will permit Parent to continue to qualify for taxation as a REIT under the Code for its taxable year which includes the Closing Date Effective Time and thereafter (which opinion shall be based upon the representation letter letters described in Section 7.13(a) and Section 7.13(b) 7.15 and shall be subject to customary assumptions, limitations and qualifications).

Opinion Relating to REIT Qualification. Company shall have received the written opinion of ▇▇▇▇▇ & ▇▇▇▇▇▇▇ Lovells US LLP (or other counsel reasonably satisfactory to Company), dated as of the Closing Date in substantially the form attached hereto as Exhibit EC, to the effect that for all taxable periods commencing with its taxable year ended December 31, 2019 and through the Closing Date2004, Parent has been organized and operated in conformity with the requirements for qualification and taxation as a REIT under the Code, and that its proposed method of past, current and intended future organization and operation will permit Parent to continue to qualify for taxation as a REIT under the Code for its taxable year which includes the Closing Date Effective Time and thereafter (which opinion shall be based upon the representation letter letters described in Section 7.13(a) and Section 7.13(b) 7.15 and shall be subject to customary assumptions, limitations and qualifications).