Re: Agreement and Plan of Reorganization, dated September 9, 2009 (the “Plan”), adopted by the Board of Trustees of the Schwab Capital Trust (the “Trust”) for the reorganization of the Trust’s Schwab Institutional Select S&P 500 Fund (the “Acquired...Agreement and Plan of Reorganization • November 25th, 2009 • Schwab Capital Trust
Contract Type FiledNovember 25th, 2009 CompanyYou have requested our opinions as to certain U.S. federal income tax consequences of the reorganization of the Acquired Fund and the Surviving Fund that will consist of: (i) the transfer of all of the assets of the Acquired Fund to the Surviving Fund in exchange solely for shares of the Surviving Fund (“Surviving Fund Shares”), (ii) the assumption by the Surviving Fund of all of the liabilities of the Acquired Fund, and (iii) the distribution of the Surviving Fund Shares to the shareholders of the Acquired Fund1 in complete liquidation of the Acquired Fund, all upon the terms and conditions set forth in the Plan (the “Reorganization”).
FORM OF OPINION]Agreement and Plan of Reorganization • August 12th, 2009 • Laudus Trust
Contract Type FiledAugust 12th, 2009 CompanyYou have requested our opinions as to certain U.S. federal income tax consequences of the reorganization of the Acquired Fund and the Surviving Fund that will consist of: (i) the transfer of all of the assets of the Acquired Fund to the Surviving Fund in exchange solely for shares of the Surviving Fund (“Surviving Fund Shares”), (ii) the assumption by the Surviving Fund of all of the liabilities of the Acquired Fund, and (iii) the distribution of the Surviving Fund Shares to the shareholders of the Acquired Fund in complete liquidation of the Acquired Fund, all upon the terms and conditions set forth in the Plan (the “Reorganization”). 1
Re: Agreement and Plan of Reorganization, dated June 16, 2009 (the “Plan”), adopted by the Board of Trustees of the Schwab Capital Trust (the “Trust”) for the reorganization of the Trust’s Schwab Retirement Income Fund (the “Acquired Fund”) into the...Agreement and Plan of Reorganization • July 29th, 2009 • Schwab Capital Trust
Contract Type FiledJuly 29th, 2009 CompanyYou have requested our opinions as to certain U.S. federal income tax consequences of the reorganization of the Acquired Fund and the Surviving Fund that will consist of: (i) the transfer of all of the assets of the Acquired Fund to the Surviving Fund in exchange solely for shares of the Surviving Fund (“Surviving Fund Shares”), (ii) the assumption by the Surviving Fund of all of the liabilities of the Acquired Fund, and (iii) the distribution of the Surviving Fund Shares to the shareholders of the Acquired Fund in complete liquidation of the Acquired Fund, all upon the terms and conditions set forth in the Plan (the “Reorganization”).
Re: Agreement and Plan of Reorganization, dated May 21, 2009 (the “Plan”), adopted by the Board of Trustees of the Schwab Capital Trust (the “Trust”) for the reorganization of the Trust’s Laudus U.S. MarketMasters Fund (the “Acquired Fund”) into the...Agreement and Plan of Reorganization • July 8th, 2009 • Schwab Capital Trust
Contract Type FiledJuly 8th, 2009 CompanyYou have requested our opinions as to certain U.S. federal income tax consequences of the reorganization of the Acquired Fund and the Surviving Fund that will consist of: (i) the transfer of all of the assets of the Acquired Fund to the Surviving Fund in exchange solely for shares of the Surviving Fund (“Surviving Fund Shares”), (ii) the assumption by the Surviving Fund of all of the liabilities of the Acquired Fund, and (iii) the distribution of the Surviving Fund Shares to the shareholders of the Acquired Fund1 in complete liquidation of the Acquired Fund, all upon the terms and conditions set forth in the Plan (the “Reorganization”).
FORM OF OPINION]Agreement and Plan of Reorganization • June 17th, 2009 • Schwab Capital Trust
Contract Type FiledJune 17th, 2009 CompanyYou have requested our opinions as to certain U.S. federal income tax consequences of the reorganization of the Acquired Fund and the Surviving Fund that will consist of: (i) the transfer of all of the assets of the Acquired Fund to the Surviving Fund in exchange solely for shares of the Surviving Fund (“Surviving Fund Shares”), (ii) the assumption by the Surviving Fund of all of the liabilities of the Acquired Fund, and (iii) the distribution of the Surviving Fund Shares to the shareholders of the Acquired Fund1 in complete liquidation of the Acquired Fund, all upon the terms and conditions set forth in the Plan (the “Reorganization”).
Re: Agreement and Plan of Reorganization, dated March 26, 2009 (the “Plan”), adopted by the Board of Trustees of the Laudus Trust (the “Trust”) for the reorganization of the Trust’s Laudus Rosenberg U.S. Large Capitalization Growth Fund (the “Acquired...Agreement and Plan of Reorganization • May 12th, 2009 • Laudus Trust
Contract Type FiledMay 12th, 2009 CompanyYou have requested our opinions as to certain U.S. federal income tax consequences of the reorganization of the Acquired Fund and the Surviving Fund that will consist of: (i) the transfer of all of the assets of the Acquired Fund to the Surviving Fund in exchange solely for Select and Investor Class shares of the Surviving Fund (“Surviving Fund Shares”), (ii) the assumption by the Surviving Fund of all of the liabilities of the Acquired Fund, and (iii) the distribution of the Surviving Fund Shares to the shareholders of the Acquired Fund1 in complete liquidation of the Acquired Fund, all upon the terms and conditions set forth in the Plan (the “Reorganization”).
FORM OF OPINION]Agreement and Plan of Reorganization • March 27th, 2009 • Schwab Capital Trust
Contract Type FiledMarch 27th, 2009 CompanyYou have requested our opinions as to certain U.S. federal income tax consequences of the reorganization of the Acquired Fund and the Surviving Fund that will consist of: (i) the transfer of all of the assets of the Acquired Fund to the Surviving Fund in exchange solely for shares of the Surviving Fund (“Surviving Fund Shares”), (ii) the assumption by the Surviving Fund of all of the liabilities of the Acquired Fund, and (iii) the distribution of the Surviving Fund Shares to the shareholders of the Acquired Fund in complete liquidation of the Acquired Fund, all upon the terms and conditions set forth in the Plan (the “Reorganization”).
FORM OF OPINION]Agreement and Plan of Reorganization • February 10th, 2009 • Schwab Capital Trust
Contract Type FiledFebruary 10th, 2009 CompanyYou have requested our opinions as to certain U.S. federal income tax consequences of the reorganization of the Acquired Fund and the Surviving Fund that will consist of: (i) the transfer of all of the assets of the Acquired Fund to the Surviving Fund in exchange solely for shares of the Surviving Fund (“Surviving Fund Shares”), (ii) the assumption by the Surviving Fund of all of the liabilities of the Acquired Fund, and (iii) the distribution of the Surviving Fund Shares to the shareholders of the Acquired Fund1 in complete liquidation of the Acquired Fund, all upon the terms and conditions set forth in the Plan (the “Reorganization”).