EX-8.2 9 file9.htm REEDER & SIMPSON TAX OPINION

Exhibit 8.2

REEDER & SIMPSON P.C.

 

RRE Commercial Center
P.O. Box 601
Majuro, MH 96960, Marshall Islands
Telephone: +692 625 3602
Fax: +692 625 3603
E-mail: dreeder@ntamar.net

 

R. Simpson
8 Karaiskaki St., Moschaton 183 45
Athens, Greece
Telephone: +30 210 941 7208
Fax: +30 210 941 4790
E-mail: simpson@otenet.gr
Mobile phone: +30 6945 465 173

October 25, 2005

Navios Maritime Partners L.P.

Attention: Angeliki Frangou

85 Akti Miaouli Street

Piraeus, Greece 185 38

 

Re:

Navios Maritime Partners L.P. Registration Statement of Form F-1

Ladies and Gentlemen:

We have acted as Marshall Islands counsel to Navios Maritime Partners L.P., a Marshall Islands limited partnership (the “Partnership”), in connection with the offer and sale by the Partnership (the “Offering”) of up to 11,500,000 common units of the Partnership (the “Common Units”) pursuant to the Registration Statement on Form F-1 relating to the Offering (the “Registration Statement”), filed by the Partnership with the Securities and Exchange Commission (the “Commission”) pursuant to the Securities Act of 1933, as amended (the “Act”), and the rules and regulations promulgated thereunder (the “Rules and Regulations”).

In connection therewith, we reviewed the discussion (the “Discussion”) set forth under the caption “Non-United States Tax Considerations—Marshall Islands Tax Consequences” in the Registration Statement.

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 hereof. 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 Republic of the Marshall Islands tax matters (except for the representations and statements of fact of the Company, 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. This consent does not constitute an

 

 



admission that we are “experts” within the meaning of such term as used in the Act or the Rules and Regulations.

 

 

 

 

Very truly yours,

 

 


/S/ Raymond E. Simpson

 

 

 

Reeder & Simpson, P.C.