Common Contracts

2 similar Agreement and Plan of Reorganization contracts by Franklin California Tax Free Income Fund, Franklin Federal Tax Free Income Fund

December 2, 2016
Agreement and Plan of Reorganization • December 7th, 2016 • Franklin Federal Tax Free Income Fund

In rendering our opinion, we have reviewed and relied upon: (a) a copy of the executed Plan, dated as of November 7, 2016; (b) the prospectus/proxy statement provided to shareholders of the Target Fund in connection with a Special Meeting of Shareholders on November 7, 2016; (c) certain representations concerning the Reorganization made to us by the Acquiring Fund and FTFT, on behalf of the Target Fund, in a letter dated December 2, 2016 (the “Representation Letter”); (d) all other documents, financial and other reports and corporate minutes we deemed relevant or appropriate; and (e) such statutes, regulations, rulings and decisions as we deemed material in rendering this opinion.

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October 28, 2016
Agreement and Plan of Reorganization • November 8th, 2016 • Franklin California Tax Free Income Fund

You have requested our opinion as to certain federal income tax consequences of the reorganization (hereinafter referred to as the “Reorganization”) of the Target Fund, which

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