Common Contracts
10 similar null contracts by Advisor Managed Portfolios, Listed Funds Trust
Re: Agreement and Plan of Reorganization, dated as of the date hereof (the “Agreement”), by and among (i) Advisor Managed Portfolios, a Delaware statutory trust (the “Acquiring Entity”) on behalf of its respective series identified on Exhibit A...Advisor Managed Portfolios • October 18th, 2023
This opinion is furnished to you pursuant to Section 8.4 of the Agreement. You have requested our opinions as to certain U.S. federal income tax consequences of the reorganization of the Acquiring Funds and the Target Funds that will consist of, with respect to each Acquiring Fund and the corresponding Target Fund (as set forth in Exhibit A hereto): (A) the Acquiring Fund acquiring the Assets (as such term is defined in Section 1.1(b) of the Agreement) of the corresponding Target Fund solely in exchange for (i) shares of the Acquiring Fund of equal value to the net assets of the Target Fund and (ii) the assumption of the Liabilities (as such term is defined in Section 1.1(c) of the Agreement), (B) the Target Fund immediately distributing such shares of the Acquiring Fund to shareholders of the Target Fund, and (C) followed immediately by the complete liquidation of the Target Fund, all upon the terms and conditions set forth in the Agreement (the foregoing transactions with respect to
Re: Agreement and Plan of Reorganization, dated as of the date hereof (the “Agreement”), by and among (i) Adviser Managed Trust, a Delaware statutory trust (the “Acquiring Entity”) on behalf of its series, the Miller Income Fund (the “Acquiring...Advisor Managed Portfolios • October 16th, 2023
This opinion is furnished to you pursuant to Section 8.4 of the Agreement. You have requested our opinions as to certain U.S. federal income tax consequences of the reorganization of the Acquiring Fund and the Target Fund that will consist of: (A) the Acquiring Fund acquiring the Assets (as such term is defined in Section 1.1(b) of the Agreement) of the Target Fund solely in exchange for (i) shares of the Acquiring Fund of equal value to the net assets of the Target Fund and (ii) the assumption of the Liabilities (as such term is defined in Section 1.1(c) of the Agreement), (B) the Target Fund immediately distributing such shares of the Acquiring Fund to shareholders of the Target Fund, and (C) followed immediately by the complete liquidation of the Target Fund, all upon the terms and conditions set forth in the Agreement (the foregoing transactions with are referred to herein as the “Reorganization”).
Re: Agreement and Plan of Reorganization, dated as of the date hereof (the “Agreement”), by and among (i) Adviser Managed Trust, a Delaware statutory trust (the “Acquiring Entity”) on behalf of its series, the Bramshill Income Performance Fund (the...Advisor Managed Portfolios • October 16th, 2023
This opinion is furnished to you pursuant to Section 8.4 of the Agreement. You have requested our opinions as to certain U.S. federal income tax consequences of the reorganization of the Acquiring Fund and the Target Fund that will consist of: (A) the Acquiring Fund acquiring the Assets (as such term is defined in Section 1.1(b) of the Agreement) of the Target Fund solely in exchange for (i) shares of the Acquiring Fund of equal value to the net assets of the Target Fund and (ii) the assumption of the Liabilities (as such term is defined in Section 1.1(c) of the Agreement), (B) the Target Fund immediately distributing such shares of the Acquiring Fund to shareholders of the Target Fund, and (C) followed immediately by the complete liquidation of the Target Fund, all upon the terms and conditions set forth in the Agreement (the foregoing transactions with are referred to herein as the “Reorganization”).
Re: Agreement and Plan of Reorganization, dated as of the date hereof (the “Agreement”), by and among (i) Adviser Managed Trust, a Delaware statutory trust (the “Acquiring Entity”) on behalf of its series, the Patient Opportunity Trust (the “Acquiring...Advisor Managed Portfolios • October 10th, 2023
This opinion is furnished to you pursuant to Section 8.4 of the Agreement. You have requested our opinions as to certain U.S. federal income tax consequences of the reorganization of the Acquiring Fund and the Target Fund that will consist of: (A) the Acquiring Fund acquiring the Assets (as such term is defined in Section 1.1(b) of the Agreement) of the Target Fund solely in exchange for (i) shares of the Acquiring Fund of equal value to the net assets of the Target Fund and (ii) the assumption of the Liabilities (as such term is defined in Section 1.1(c) of the Agreement), (B) the Target Fund immediately distributing such shares of the Acquiring Fund to shareholders of the Target Fund, and (C) followed immediately by the complete liquidation of the Target Fund, all upon the terms and conditions set forth in the Agreement (the foregoing transactions with are referred to herein as the “Reorganization”).
Re: Agreement and Plan of Reorganization, dated as of the date hereof (the “Agreement”), by and among (i) Adviser Managed Trust, a Delaware statutory trust (the “Acquiring Entity”) on behalf of its series, the Regan Total Return Income Fund (the...Advisor Managed Portfolios • September 29th, 2023
This opinion is furnished to you pursuant to Section 8.4 of the Agreement. You have requested our opinions as to certain U.S. federal income tax consequences of the reorganization of the Acquiring Fund and the Target Fund that will consist of: (A) the Acquiring Fund acquiring the Assets (as such term is defined in Section 1.1(b) of the Agreement) of the Target Fund solely in exchange for (i) shares of the Acquiring Fund of equal value to the net assets of the Target Fund and (ii) the assumption of the Liabilities (as such term is defined in Section 1.1(c) of the Agreement), (B) the Target Fund immediately distributing such shares of the Acquiring Fund to shareholders of the Target Fund, and (C) followed immediately by the complete liquidation of the Target Fund, all upon the terms and conditions set forth in the Agreement (the foregoing transactions with are referred to herein as the “Reorganization”).
Re: Agreement and Plan of Reorganization, dated as of the date hereof (the “Agreement”), by and among (i) Advisor Managed Portfolios, a Delaware statutory trust (the “Acquiring Entity”) on behalf of its respective series identified on Exhibit A...Advisor Managed Portfolios • September 27th, 2023
This opinion is furnished to you pursuant to Section 8.4 of the Agreement. You have requested our opinions as to certain U.S. federal income tax consequences of the reorganization of the Acquiring Fund and the Target Fund that will consist of, with respect to each Acquiring Fund and the corresponding Target Fund (as set forth in Exhibit A hereto): (A) the Acquiring Fund acquiring the Assets (as such term is defined in Section 1.1(b) of the Agreement) of the corresponding Target Fund solely in exchange for (i) shares of the Acquiring Fund of equal value to the net assets of the Target Fund and (ii) the assumption of the Liabilities (as such term is defined in Section 1.1(c) of the Agreement), (B) the Target Fund immediately distributing such shares of the Acquiring Fund to shareholders of the Target Fund, and (C) followed immediately by the complete liquidation of the Target Fund, all upon the terms and conditions set forth in the Agreement (the foregoing transactions with respect to ea
Morgan, Lewis & Bockius llp1111 Pennsylvania Avenue, NWWashington, DC 20004-2541www.morganlewis.comAdvisor Managed Portfolios • September 12th, 2023
This opinion is furnished to you pursuant to Section [8.4] of the Agreement. You have requested our opinions as to certain U.S. federal income tax consequences of the reorganization of the Acquiring Fund and the Target Fund that will consist of: (A) the Acquiring Fund acquiring the Assets (as such term is defined in Section 1.1(b) of the Agreement) of the Target Fund solely in exchange for (i) shares of the Acquiring Fund of equal value to the net assets of the Target Fund and (ii) the assumption of the Liabilities (as such term is defined in Section 1.1(c) of the Agreement), (B) the Target Fund immediately distributing such shares of the Acquiring Fund to shareholders of the Target Fund, and (C) followed immediately by the complete liquidation of the Target Fund, all upon the terms and conditions set forth in the Agreement (the foregoing transactions with are referred to herein as the “Reorganization”).
Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004-2541 www.morganlewis.comListed Funds Trust • April 3rd, 2023
Morgan, Lewis & Bockius LLP 1111 Pennsylvania Avenue, NW Washington, DC 20004-2541 www.morganlewis.comListed Funds Trust • October 28th, 2022
Morgan, Lewis & Bockius llp1111 Pennsylvania Avenue, NWWashington, DC 20004-2541www.morganlewis.comListed Funds Trust • October 21st, 2022
