Expense Limitation Agreement August 9, 2010Expense Limitation Agreement • October 7th, 2010 • Dblaine Investment Trust
As of November [•], 2010Agreement and Plan of Reorganization • October 7th, 2010 • Dblaine Investment Trust
You have requested our opinion as to certain United States (“U.S.”) federal income tax consequences of the reorganization of the Acquired Funds and the Acquiring Fund (the "Reorganization"). The Reorganization will involve the transfer of all of the assets of the Acquired Funds to the Acquiring Fund, and the assumption of the liabilities of the Acquired Funds by the Acquiring Fund in exchange for Class A Shares of the Acquiring Fund. The Class A Shares of the Acquiring Fund will be distributed to the shareholders of the Acquired Funds and after completion of the Reorganization, each shareholder of the Acquired Funds will own Class A Shares of the Acquiring Fund equal in dollar value to the current net asset value of such shareholder’s shares of the Acquired Funds. Additionally, the Acquired Funds will be liquidated under Delaware state law.
