Exhibit 8.2
REEDER & SIMPSON, P.C.
ATTORNEYS AT LAW
| P.O. Box 601 | RMI Tel.:+692-625-3602 | |||
| RRE Commercial Center | Honolulu Tel.:808-352-0749 | |||
| Majuro, MH 96960 | Email: dreeder.rmi@gmail.com | |||
| Marshall Islands |
February 27, 2020
Atlas Corp.
2600-200 Granville Street
Vancouver, BC V6C 1S4
Canada
Re: Atlas Corp.
Ladies and Gentlemen:
We have acted as Republic of the Marshall Islands (the “RMI”), counsel to Atlas Corp., a corporation formed under the laws of the RMI (the “Corporation”), in connection with the filing of Post-Effective Amendment No. 1 to Registration Statement on FormF-3, FileNo. 333-229312, as amended the “Registration Statement”), with the Securities and Exchange Commission (the “Commission”), relating to the registration of 52,810,939 common shares, par value US$0.01 per share of the Corporation.
In connection therewith, we have prepared the discussion included in the Registration Statement under the caption “MaterialNon-United States Tax Considerations – Material Republic of the Marshall Islands Tax Considerations” (the “Discussion”), and we hereby confirm that the Discussion sets forth our opinion with respect to the matters set forth therein as of the date of the Registration Statement.
We hereby consent to the filing of this opinion as an exhibit to the Registration Statement and to the reference to us and this opinion in the Registration Statement. This consent does not constitute an admission that we are an “expert” within the meaning of such term as used in the Securities Act or the rules and regulations of the Commission thereunder.
| Very truly yours, |
 |
| Dennis J. Reeder |
| Reeder & Simpson, P.C. |