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EXHIBIT 8
DUANE MORRIS FIRM AND AFFILIATE OFFICES
NEW YORK
LONDON
CHICAGO
HOUSTON
PHILADELPHIA
SAN FRANCISCO
BOSTON
WASHINGTON, DC
ATLANTA
MIAMI
NEWARK
ALLENTOWN
WILMINGTON
CHERRY HILL
HARRISBURG
BANGOR
PRINCETON
PALM BEACH
WESTCHESTER
May 6, 2003
Board of Directors
Inland Western Retail Real Estate Trust, Inc.
2901 Butterfield Road
Oak Brook, IL 60523
INLAND WESTERN RETAIL REAL ESTATE TRUST, INC.
Ladies and Gentlemen:
You have requested our opinions with respect to all material Federal income
tax matters in connection with the proposed offering (the "Offering") of
270,000,000 shares of common stock (the "Shares") of Inland Western Retail Real
Estate Trust, Inc. a Maryland corporation (the "Company"), as a more fully
described in the registration statement on Form S-11, (the "Registration
Statement"), and the prospectus included therein ("the "Prospectus"), to be
filed by the Company with the Securities and Exchange Commission on May 7,
2003. All terms used herein have the respective meanings set forth in the
Prospectus.
We have acted as counsel to the Company with respect to the Offering of its
shares of common stock (the "Shares"). This letter is for delivery in connection
with the proposed Offering of Shares made by the Prospectus and is intended to
confirm as of the date hereof certain opinions described in the "Federal Income
Tax Considerations" section of the Prospectus. This letter and the opinions
expressed or confirmed herein are for delivery to the Company and may be relied
upon only by it and its Shareholders who acquire their Shares from the Company.
In rendering our opinions, we have reviewed and relied upon the
Registration Statement and exhibits to the Registration Statement, including the
Charter and Bylaws, each as amended. In addition, we have relied upon the letter
from the Company to this firm, dated May 6, 2003 representing the truth and
accuracy of the representations attributed to it in the Prospectus, we have had
discussions with executive personnel of the Company, and we have examined and
relied upon such records, documents, certificates, instructions, resolutions,
and other matters which, in our judgment, were necessary in order to enable us
to render the opinions herein set forth.
DUANE MORRIS LLP
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ONE LIBERTY PLACE PHILADELPHIA, PA 19103 PHONE 215.979.1000 FAX: 215.978.1020
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Inland Western Retail Real Estate Trust, Inc.
May 6, 2003
Page 2
Based on the foregoing and in reliance thereon and subject thereto and on
an analysis of the Internal Revenue Code of 1986, as amended (the "Code"),
Treasury Regulations thereunder, judicial authority and current administrative
rulings and such other laws and facts as we have deemed relevant and necessary,
we hereby confirm our opinion that, commencing with the Company's initial
taxable year that will end on December 31, 2003, the Company has been organized
in conformity with the requirements for qualification as a REIT under the Code,
and that its method of operation through the date of this letter has enabled,
and its proposed method of operation will enable, it to satisfy the requirements
for qualification and taxation as a REIT. This opinion represents our legal
judgment, but it has no binding effect or official status of any kind, and no
assurance can be given that contrary positions may not be taken by the Internal
Revenue Service or a court.
The Company's qualification as a REIT will depend upon the continuing
satisfaction by the Company of the requirements of the Code relating to
qualification for REIT status, which requirements include those that are
dependent upon actual operating results, distribution levels, diversity of stock
ownership, asset composition, source of income and record keeping. We do not
undertake to monitor whether the Company actually has satisfied or will satisfy
the various REIT qualification tests.
Furthermore, we hereby confirm to you that, in our opinion, insofar as they
purport to describe provisions of United States Federal income tax law, the
statements set forth under the caption "Federal Income Tax Considerations" in
the Prospectus included in the Registration Statement is accurate in all
material respects.
We hereby consent to the filing with the Securities and Exchange Commission
of this letter as an exhibit to the Registration Statement of which the
Prospectus is a part and the reference to us under the caption "Federal Income
Tax Considerations". In giving such consent, we do not thereby admit that we are
within the category of persons whose consent is required under Section 7 of the
Securities Act.
Sincerely,
/s/ DUANE MORRIS LLP
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DUANE MORRIS LLP