EX-8.2 4 d553187dex82.htm EX-8.2 EX-8.2

Exhibit 8.2

REEDER & SIMPSON, P.C.

ATTORNEYS AT LAW

 

P.O. Box 601

RRE Commercial Center

Majuro, MH 96960

Marshall Islands

     

RMI Tel.: +692-625-3602

Honolulu Tel.: 808-352-0749

Email: dreeder.rmi@gmail.com               r.simpson@simpson.gr

April 13, 2018

Seaspan Corporation

Unit 2, 2nd Floor, Bupa Centre

141 Connaught Road West

Hong Kong, China

 

  Re: Seaspan Corporation– Registration Statement on Form F-3

Ladies and Gentlemen:

We have acted as Republic of the Marshall Islands (the “RMI”), counsel to Seaspan Corporation, a non-resident domestic corporation formed under the laws of the RMI (the “Corporation”), in connection with the offer and sale of 5,000,000 Class A common shares (the “Common Shares”), pursuant to a Registration Statement filed by the Corporation on Form F-3 with the Securities and Exchange Commission (the “Commission”), pursuant to the Securities Act of 1933, as amended, through the date hereof (the “Registration Statement”), and the prospectus (the “Prospectus”), of the Corporation included in the Registration Statement.

In connection therewith, we have prepared the discussion regarding Marshall Islands tax consequences set forth in each Prospectus under the captions “Material Non-United States Tax Considerations—Material Marshall Islands Tax Consequences” and “Material Non-United States Tax Considerations—Material Canadian Federal Income Tax Considerations” (the “Discussion”).

With respect to the Canadian Federal Income Tax Considerations we can confirm that a Canadian resident corporation that carries on international shipping business, as described in the Discussion is exempt from all RMI income taxes under the current laws of the RMI. All statements of legal conclusions contained in the Discussion, unless otherwise noted, are our opinion with respect to the matters set forth therein as of the date of the Prospectuses. In addition, we are of the opinion that the Discussion, with respect to those matters as to which no legal conclusions are provided, is an accurate discussion of such RMI tax matters (except for the representations and statements of fact of the Corporation, included in the Discussion, as to which we express no opinion).


We hereby consent to the filing of this opinion as an exhibit to the Registration Statement and to the use of our name in the Registration Statement and the Prospectus. This consent does not constitute an admission that we are an “expert” within the meaning of such term as used in the Securities Act of 1933, as amended, or the rules and regulations of the Commission issued thereunder.

 

Very truly yours,
/s/    Dennis J. Reeder        

Dennis J. Reeder

Reeder & Simpson, P.C.