January 11, 2007 The Alger Institutional Funds on behalf of Alger Green Institutional Fund 111 Fifth Avenue New York, New York 10003 The Spectra Funds on behalf of Spectra Green Fund 111 Fifth Avenue New York, New York 10003 Re: Agreement and Plan of...Agreement and Plan of Reorganization • December 20th, 2007 • Spectra Funds
You have requested our opinion as to certain federal income tax consequences of the reorganization contemplated by the Agreement and Plan of Reorganization (the "Plan") adopted by The Alger Institutional Funds (the "Trust"), a Massachusetts business trust, on behalf of its series Alger Institutional Green Fund (the "Fund"), and The Spectra Funds (formerly, Spectra Fund) (the "Acquiring Trust"), a Massachusetts business trust, on behalf of its series Spectra Green Fund (the "Acquiring Fund"). A copy of the Plan is included as Appendix A to the Registration Statement on Form N-14 of the Fund (Registration No. 333-138308) (the "Registration Statement"). You have advised us that each of the Fund and the Acquiring Fund has qualified or will qualify as a "regulated investment company" within the meaning of Subchapter M of the United States Internal Revenue Code of 1986, as amended (the "Code"), for each of its fiscal years of operation ending on or before or including the Closing Date.
