Exhibit 8.3
September 19, 2018
Seaspan Corporation
Unit 2, 2nd Floor, Bupa Centre
141 Connaught Road West
Hong Kong, China
Dear Sirs/Mesdames:
| Re: | Seaspan Corporation – Prospectus Supplement |
We have acted as Canadian tax counsel to Seaspan Corporation (the “Company”), a corporation formed under the laws of the Republic of the Marshall Islands, with respect to certain legal matters in connection with the filing of the Company’s Prospectus Supplement, dated September 12, 2018 (the “Prospectus Supplement”), with the Securities and Exchange Commission (the “Commission”) for the issue and sale by the Company of 6,000,000 of its Series IFixed-to-Floating Rate Cumulative Redeemable Perpetual Preferred Shares, par value $0.01 per share, liquidation preference $25.00 per share.
In connection therewith, we have reviewed the discussion set forth under the caption “MaterialNon-United States Tax Considerations – Canadian Federal Income Tax Considerations” in the Prospectus Supplement (the “Discussion”).
Subject to the limitations, qualifications, assumptions and caveats set forth herein and in the Prospectus Supplement, we hereby confirm our opinions set forth in the Discussion as of the effective date of the Prospectus Supplement (except for the representations and statements of fact of the Company and the statements of Marshall Islands law, included in the Discussion, as to which we express no opinion). In delivery of this opinion, we have relied upon an Officer’s Certificate duly executed by an officer of the Company as to the matters certified therein. We have made no independent investigation or verification of the statement and representations contained in the Officer’s Certificate and have assumed that the information therein is true, accurate and complete.
We hereby consent to the filing of this opinion as an exhibit to the Prospectus Supplement and to the use of our name in the Prospectus Supplement. This consent does not constitute an admission that we are “experts” 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.
Yours truly,
/s/ Blake, Cassels & Graydon LLP
