FORM OF OPINION RE: TAX MATTERSAgreement and Plan of Reorganization • July 23rd, 2020 • Diamond Hill Funds
Re: AGREEMENT AND PLAN OF REORGANIZATION, DATED AS OF JULY 21, 2020 (THE "AGREEMENT"), BY AND BETWEEN DIAMOND HILL FUNDS ("DIAMOND HILL") ON BEHALF OF ITS SERIES, DIAMOND HILL RESEARCH OPPORTUNITIES FUND (THE "TRANSFERRING FUND") AND ITS SERIES, DIAMOND HILL LONG-SHORT FUND (THE "ACQUIRING FUND") AND, SOLELY FOR PURPOSES OF PARAGRAPH 5 THEREOF, DIAMOND HILL CAPITAL MANAGEMENT, INC. ("DHCM")
AGREEMENT AND PLAN OF REORGANIZATIONReorganization Agreement • July 23rd, 2020 • Diamond Hill Funds • Ohio
THIS AGREEMENT AND PLAN OF REORGANIZATION (the “Agreement”) is made as of this twenty-first day of July, 2020 by and between Diamond Hill Funds, an Ohio business trust (the “Trust”), on behalf of Diamond Hill Research Opportunities Fund, a series of the Trust (the “Target Fund”), and Diamond Hill Long-Short Fund, a series of the Trust (the “Acquiring Fund”). Diamond Hill Capital Management, Inc. (“DHCM”) joins this agreement solely for the purpose of agreeing to be bound by Paragraph 5.
