Common use of Opinion Relating to REIT Qualification Clause in Contracts

Opinion Relating to REIT Qualification. CPA14 shall have received an opinion, dated as of the Closing Date, of ▇▇▇▇▇▇▇▇ Chance US LLP to the effect that, at all times since its taxable year ended December 31, 2007, CPA16 has been organized and operated in conformity with the requirements for qualification and taxation as a REIT under the Code, and its proposed method of operation as described in the Joint Proxy Statement/Prospectus and Form S-4 will enable CPA16 to meet the requirements for qualification and taxation as a REIT under the Code. For purposes of such opinion, ▇▇▇▇▇▇▇▇ Chance US LLP may rely on customary assumptions and representations of CPA16 reasonably acceptable to CPA14, and the opinion set forth in Section 5.2(d).

Opinion Relating to REIT Qualification. CPA14 CPA:12 shall have received an opinion, dated as of the Closing Date, of ▇C▇▇▇▇▇▇▇ Chance US LLP to the effect that, at all times since its taxable year ended December 31, 20072002, CPA16 CPA:14 has been organized and operated in conformity with the requirements for qualification and taxation as a REIT under the Code, and its proposed method of operation as described in the Joint Proxy Statement/Prospectus and Form S-4 will enable CPA16 CPA:14 to meet the requirements for qualification and taxation as a REIT under the Code. For purposes of such opinion, ▇C▇▇▇▇▇▇▇ Chance US LLP may rely on customary assumptions and representations of CPA16 CPA:14 reasonably acceptable to CPA14CPA:12, and the opinion set forth in Section 5.2(d).