September 15, 1999 Excelsior Funds, Inc. Excelsior Funds 73 Tremont Street Boston, MA 02108-3913 RE: Agreement and Plan of Reorganization By and Between Excelsior Funds, Inc. and Excelsior Funds --------------------------------------------------------...Agreement and Plan of Reorganization • September 15th, 1999 • Excelsior Funds Inc
You have asked for our opinion on the federal income tax consequences to shareholders of the transactions contemplated in the above Agreement and Plan of Reorganization. In our opinion, the material federal income tax consequences to shareholders of such transactions are accurately set forth in the subsection entitled "INFORMATION RELATING TO THE PROPOSED REORGANIZATION - Federal Income Tax Consequences" in the Combined Prospectus/Proxy Statement contained in the Registration Statement being filed this day with the Securities and Exchange Commission.
