EX-8.2 19 v220791_ex8-2.htm FORM OF OPINION OF LKP GLOBAL LAW, LLP REGARDING CERTAIN U.S. FEDERAL TAX MATTE Unassociated Document
[LETTERHEAD OF LKP GLOBAL LAW, LLP]
 
[DATE], 2011
 
Grand Farm Inc.
[ADDRESS]
China
 
Dear Ladies and Gentlemen:
 
We are acting as United States counsel to Grand Farm Inc., a company incorporated under the laws of the Cayman Islands (the “Company”), in connection with the preparation of the registration statement on Form F-1 (the “Registration Statement”) and the related prospectus (the “Prospectus”) with respect to the Company’s American depositary shares representing the Company’s ordinary shares to be offered in the Company’s initial public offering.  The Company is filing the Registration Statement with the Securities and Exchange Commission under the Securities Act of 1933, as amended.

We have examined such matters of fact and law as we have deemed necessary or advisable for the purpose of this opinion.

We hereby confirm our opinion set forth under the caption “Taxation” relating to the statements or legal conclusions set forth under the caption “Taxation—United States Federal Income Taxation” in the Prospectus.

We are members of the Bar of the State of California, and we express no opinion as to the laws of any jurisdiction other than the laws of the State of California and the federal laws of the United States.

We hereby consent to the use of our name under the captions “Taxation” and “Legal Matters” in the Prospectus included in the Registration Statement and to the filing, as an exhibit to the Registration Statement, of this opinion.

In giving such consent we do not admit that we come within the category of persons whose consent is required under Section 7 of the Securities Act of 1933, as amended.
 
Very truly yours,

 
LKP Global Law, LLP