AGREEMENT AND PLAN OF REORGANIZATION THIS AGREEMENT AND PLAN OF REORGANIZATION (the "Agreement") is made as of the 29th day of October, 2004, by and between Pioneer America Income Trust, a Massachusetts business trust (the "Acquiring Trust"), on...Reorganization Agreement • April 29th, 2005 • Pioneer America Income Trust • Delaware
GRAPHIC OMITTED][GRAPHIC OMITTED] December 10, 2004 Pioneer America Income Trust 60 State Street Boston, MA 02109 Safeco Taxable Bond Trust 5069 154th Place N.E. Redmond, Washington 98052 Ladies and Gentlemen: This opinion is being delivered to you in...Agreement and Plan of Reorganization • April 29th, 2005 • Pioneer America Income Trust
This opinion is being delivered to you in connection with the Agreement and Plan of Reorganization (the "Agreement") made as of October 29, 2004 by and between Pioneer America Income Trust, a Massachusetts business trust, on behalf of its sole series, Pioneer America Income Trust ("Acquiring Fund"), and Safeco Taxable Bond Trust, a Delaware statutory trust, on behalf of its series, Safeco Intermediate-Term U.S. Government Fund ("Acquired Fund"). Pursuant to the Agreement, Acquiring Fund will acquire all of the assets of Acquired Fund in exchange solely for (i) the assumption by Acquiring Fund of all of the Assumed Liabilities, as defined in the Agreement (the "Acquired Fund Liabilities"), and (ii) the issuance of Investor Class shares of beneficial interest of Acquiring Fund (the "Acquiring Fund Shares") to Acquired Fund, followed by the distribution by Acquired Fund, in liquidation of Acquired Fund, of the Acquiring Fund Shares to the shareholders of Acquired Fund and the termination
