September 12, 2008Agreement and Plan of Reorganization • October 31st, 2008 • Bny Mellon Funds Trust
September 12, 2008 BNY Hamilton Funds, Inc., on behalf of BNY Hamilton International Equity FundAgreement and Plan of Reorganization • October 31st, 2008 • Bny Mellon Funds Trust
September 12, 2008Agreement and Plan of Reorganization • October 31st, 2008 • Bny Mellon Funds Trust
September 12, 2008 BNY Hamilton Funds, Inc., on behalf of BNY Hamilton Small Cap Growth Fund Columbus, Ohio 43219 BNY Mellon Funds Trust, on behalf of BNY Mellon Small Cap Stock Fund New York, New York 10166Agreement and Plan of Reorganization • October 31st, 2008 • Bny Mellon Funds Trust
You have requested our opinion as to certain Federal income tax consequences of the reorganization contemplated by the Agreement and Plan of Reorganization between BNY Hamilton Funds, Inc. (the “Company”), a Maryland corporation, on behalf of BNY Hamilton Small Cap Growth Fund (the “Fund”), and BNY Mellon Funds Trust (the “Trust”), a Massachusetts business trust, on behalf of BNY Mellon Small Cap Stock Fund (the “Acquiring Fund”). A copy of the form of Agreement and Plan of Reorganization is included as Exhibit B to the Trust’s Registration Statement on Form N-14 (Registration No. 333-149912) (the “Registration Statement”).
