Drinker Biddle & Reath LLP One Logan Square, Suite 2000 Philadelphia, PA 19103Agreement and Plan of Reorganization • May 28th, 2010 • Northern Funds
Contract Type FiledMay 28th, 2010 CompanyWe have acted as counsel to the Transferor Fund and the Acquiror Fund (collectively, the “Funds”), each a series of Northern Funds, a Delaware statutory trust (the “Trust”), in connection with the transfer of all of the assets and liabilities of the Transferor Fund to the Acquiror Fund, followed by the distribution by the Transferor Fund to its shareholders of the Acquiror Fund shares (collectively, the “Reorganization”), pursuant to the Plan of Reorganization, dated December 14, 2009, adopted by the Trust and the Funds (the “Plan”). You have asked for our opinion as to certain Federal income tax consequences of the Reorganization. (All capitalized terms used but not otherwise defined in this letter shall have the meanings ascribed to them in the Plan.)
Drinker Biddle & Reath LLP One Logan SquareAgreement and Plan of Reorganization • January 22nd, 2010 • Northern Funds
Contract Type FiledJanuary 22nd, 2010 Company