Attached files
file | filename |
---|---|
S-1/A - FORM S-1/A - RIDGEBURY TANKERS LTD | y85353a4sv1za.htm |
EX-21 - EX-21 - RIDGEBURY TANKERS LTD | y85353a4exv21.htm |
EX-4.2 - EX-4.2 - RIDGEBURY TANKERS LTD | y85353a4exv4w2.htm |
EX-5.1 - EX-5.1 - RIDGEBURY TANKERS LTD | y85353a4exv5w1.htm |
EX-4.1 - EX-4.1 - RIDGEBURY TANKERS LTD | y85353a4exv4w1.htm |
EX-3.2 - EX-3.2 - RIDGEBURY TANKERS LTD | y85353a4exv3w2.htm |
EX-23.3 - EX-23.3 - RIDGEBURY TANKERS LTD | y85353a4exv23w3.htm |
EX-23.6 - EX-23.6 - RIDGEBURY TANKERS LTD | y85353a4exv23w6.htm |
EX-23.4 - EX-23.4 - RIDGEBURY TANKERS LTD | y85353a4exv23w4.htm |
EX-23.7 - EX-23.7 - RIDGEBURY TANKERS LTD | y85353a4exv23w7.htm |
EX-23.2 - EX-23.2 - RIDGEBURY TANKERS LTD | y85353a4exv23w2.htm |
EX-23.5 - EX-23.5 - RIDGEBURY TANKERS LTD | y85353a4exv23w5.htm |
EX-10.10 - EX-10.10 - RIDGEBURY TANKERS LTD | y85353a4exv10w10.htm |
Exhibit 8.1
Form of Tax Opinion
Form of Tax Opinion
[Seward & Kissel LLP Letterhead]
Ridgebury Tankers Ltd 625 Ridgebury Road Ridgefield, Connecticut 06877 |
November 19, 2010 |
Re: | Ridgebury Tankers Ltd |
Ladies and Gentlemen:
We have acted as counsel to Ridgebury Tankers Ltd (the Company) in connection with the
Companys Registration Statement on Form S-1 (File No. 333-167977) (the Registration Statement)
as filed with the U.S. Securities and Exchange Commission (the Commission) on ,
2010, as thereafter amended or supplemented, with respect to the public offering (the Offering)
of up to of the Companys Common Shares, par value $0.01 per share (the Common Shares).
In formulating our opinion as to these matters, we have examined such documents as we have
deemed appropriate, including the Registration Statement and the prospectus of the Company (the
Prospectus) included in the Registration Statement. We also have obtained such additional
information as we have deemed relevant and necessary from representatives of the Company.
Capitalized terms not defined herein have the meanings ascribed to them in the Registration
Statement.
Based on the facts as set forth in the Registration Statement and, in particular, on the
representations, covenants, assumptions, conditions and qualifications described under the captions
Risk Factors and Tax Considerations therein, we hereby confirm that the opinions of Seward &
Kissel LLP with respect to United States federal income tax matters and Marshall Islands tax
matters are those opinions attributed to Seward & Kissel LLP expressed in the Registration
Statement under the captions Tax Considerations and Risk Factors We may have to pay tax on
United States source income, which would reduce our earnings, Risk Factors U.S. tax
authorities could treat us as a passive foreign investment company, which could have adverse U.S.
federal income tax consequences to U.S. holders of our common shares and Risk Factors If we
are treated as a controlled foreign corporation, U.S. Holders could have certain adverse U.S.
federal income tax consequences in the Registration Statement accurately state our opinion as to
the tax matters discussed therein.
Our opinions and the tax discussion as set forth in the Registration Statement are based on
the current provisions of the Internal Revenue Code of 1986, as amended, the Treasury Regulations
promulgated thereunder, published pronouncements of the Internal Revenue Service which may be cited
or used as precedents, and case law, any of which may be changed at any time with retroactive
effect. No opinion is expressed on any matters other than those specifically referred to above by
reference to the Registration Statement.
We hereby consent to the filing of this opinion as an exhibit to the Registration Statement.
Very truly yours,