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Title: |
Opinion Letter |
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Entities: |
Hospitality Properties Trust; InterContinental Hotels Group plc; Intercontinental Hotels Group Resources, Inc.; Wyndham International, Inc.; Securities Exchange Commission; Candlewood Management, LLC; HPT TRS SPES, Inc. |
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Date: |
2003 |
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Size: |
7KB total |
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Price: |
$38 |
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ID: |
#268333 |
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July 7, 2003
Hospitality Properties Trust
400 Centre Street
Newton, Massachusetts 02458
Ladies and Gentlemen:
The following opinion is furnished to Hospitality Properties Trust, a Maryland real estate investment trust (the ?Company?) to be filed with the Securities Exchange Commission (the ?SEC?) as Exhibit 8.1 to the Company?s Current Report on Form 8-K (the ?Form 8-K?), to be filed within one week of the date hereof, under the Securities Exchange Act of 1934, as amended (the ?Exchange Act?).
In connection with this opinion, we have reviewed originals or copies, certified or otherwise identified to our satisfaction, of corporate records, certificates and statements of officers and accountants of the Company and of public officials, and such other documents as we have considered relevant and necessary in order to furnish the opinion hereinafter set forth. In doing so, we have assumed the genuineness of all signatures, the legal capacity of natural persons, the authenticity of all documents submitted to us as originals, the conformity to original documents of all documents submitted to us as copies, and the authenticity of the originals of such documents. Specifically, and without limiting the generality of the foregoing, we have reviewed: (i) the declaration of trust and the by-laws of the Company, each as amended and restated; (ii) the section in the Company?s Annual Report on Form 10-K for the year ended December 31, 2002 filed under the Exchange Act (the ?Annual Report?) captioned ?Federal Income Tax Considerations?; (iii) the section in the Form 8-K captioned ?Supplementary federal income tax considerations?; (iv) the master lease agreement between HPTSHC Properties Trust (?HPTSHC?), a wholly-owned subsidiary of the Company, and HPT TRS SPES, Inc. (?HPT TRS SPES?), also a wholly-owned subsidiary of the Company, for 15 hotels formerly leased by HPTSHC to Wyndham International, Inc. or its subsidiaries (?Wyndham?) and formerly operated by Wyndham; (v) the management agreement pursuant to which these properties are operated on behalf of HPT TRS SPES by Candlewood Management, LLC; (vi) the master lease agreement between HPTWN Properties Trust (?HPTWN?), a wholly-owned subsidiary of the
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