Troutman Pepper Hamilton Sanders LLP 301 Carnegie Center, Suite 400 Princeton, NJ 08540-6227 troutman.com March 26, 2021 Board of Trustees Wells Fargo Funds Trust 525 Market Street San Francisco, California 94105 Re: Agreement and Plan of...Wells Fargo Funds Trust • April 20th, 2021
You have requested our opinion concerning certain federal income tax consequences of the reorganization of the Acquired Fund pursuant to which: (i) the Acquired Fund will transfer of all of its assets, property and goodwill in exchange for Class A shares, Class C shares or Institutional Class shares, as applicable (collectively, “Acquiring Fund Shares”), which are voting securities, of the Acquiring Fund; (ii) the Acquiring Fund will assume all of the liabilities of the Acquired Fund; and (iii) the Acquired Fund will distribute Acquiring Fund Shares to the holders of Class A shares, Class C shares or Institutional Class shares of the Acquired Fund, which are voting securities of the Acquired Fund; and (iv) the Acquired Fund will completely liquidate, all pursuant to the terms and conditions set forth in the Agreement (such transaction, the “Reorganization”).
