Form of Opinion of Bennett Jones LLP] [Bennett Jones LLP Letterhead]Merger Agreement • September 25th, 2008 • Precision Drilling Trust • Drilling oil & gas wells
Re: Agreement and Plan of Merger (the “Merger Agreement”) dated as of August 24, 2008 by and between Precision Drilling Trust, Grey Wolf, Inc., Precision Drilling Corporation and Precision Lobos Corporation
Form of Opinion of Felesky Flynn LLP] [Felesky Flynn LLP Letterhead]Agreement and Plan of Merger • September 25th, 2008 • Precision Drilling Trust • Drilling oil & gas wells
We have acted as Canadian tax counsel to Precision Drilling Trust, an Alberta unincorporated open-ended investment trust (“Precision”), in connection with the Registration Statement on Form F-4 (the “Registration Statement”) (Registration No. [ ]- ) filed by Precision with the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended, relating to the merger (the “Merger”) contemplated by the Agreement and Plan of Merger, dated as of August 24, 2008 (including the exhibits thereto, the “Merger Agreement”) by and among Precision, Grey Wolf, Inc., a Texas corporation (“Grey Wolf”), Precision Drilling Corporation, an Alberta corporation and a direct, wholly-owned subsidiary of Precision (“PDC”), and Precision Lobos Corporation, a Texas corporation and a direct wholly-owned subsidiary of Precision (“Precision Merger Sub”). This opinion is being delivered in connection with the Registration Statement, to which this opinion appears as an exhibit.
