Exhibit 8.3
March 19, 2021
Atlas Corp.
23 Berkeley Square
London, W1J 6HE
Re: Atlas Corp.
Dear Sirs,
We have acted as United Kingdom tax counsel to Atlas Corp., a corporation incorporated under the laws of the Republic of the Marshall Islands (the “Company”), in connection with the preparation of the Registration Statement on Form F-4 of the Company, including the prospectus contained therein (the “Registration Statement”), relating to the registration under the U.S. Securities Act of 1933, as amended (the “Securities Act”), of up to US$80,000,000 principal amount of 7.125% Notes due 2027 (the “ATCO Notes”) to be issued by the Company in connection with an offer by the Company to exchange (the “Exchange Offer”) the ATCO Notes for any and all outstanding US$80,000,000 principal amount of 7.125% Notes due 2027 issued by Seaspan Corporation (the “Seaspan Notes”).
Subject to the limitations, qualifications, assumptions and caveats set forth herein and in the Registration Statement, we hereby confirm that the discussions set forth under the caption “Certain U.K. Tax Considerations” in the Registration Statement set forth our opinion with respect to the material United Kingdom tax considerations applicable to the Exchange Offer and the ownership of the ATCO Notes and the Seaspan Notes.
We express no opinion as to the laws of any jurisdiction other than the laws of the United Kingdom.
We hereby consent to the filing of this opinion as an exhibit to the Registration Statement and to the references to our firm name in the Registration Statement in connection with the references to this opinion and the material United Kingdom tax considerations applicable to the ownership of the ATCO Notes. 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 Securities and Exchange Commission issued thereunder.
Yours faithfully
/s/ DLA Piper UK LLP
DLA Piper UK LLP
