ContractMerger Agreement • June 25th, 2021 • Smartfinancial Inc. • National commercial banks
You have requested our opinion regarding certain U.S. federal income tax consequences of the merger contemplated by the Agreement and Plan of Merger, dated as of April 13, 2021, (the “Merger Agreement”), between SmartFinancial, Inc., a Tennessee corporation (“SMBK”), and Sevier County Bancshares, Inc., a Tennessee corporation (“SCB”), pursuant to which SCB will merge with and into SMBK, with SMBK surviving (the “Merger”). We are rendering this opinion in connection with the filing of the Registration Statement (as may be amended from time to) with the U.S. Securities and Exchange Commission (the “SEC”). All capitalized terms used but not defined herein shall have the meanings set forth in the Merger Agreement.
