ContractPlan of Reorganization • September 26th, 2024 • Dimensional Investment Group Inc • Maryland
EX-99.12.aAgreement and Plan of Reorganization • September 26th, 2024 • Dimensional Investment Group Inc
You have requested our opinion as to certain federal income tax consequences of the Reorganization of the Target Portfolio, which will consist of: (i) the acquisition by Acquiring Corporation, on behalf of Acquiring Portfolio, of substantially all of the property, assets, and goodwill of Target Portfolio in exchange solely for full and fractional shares of capital stock, with a par value of one cent ($0.01) per share, of Acquiring Portfolio (“Acquiring Portfolio Shares”); (ii) the distribution of Acquiring Portfolio Shares to the holders of shares of capital stock of Target Portfolio (“Target Portfolio Shares”) according to their respective interests in Target Portfolio, in complete liquidation of Target Portfolio; and (iii) the dissolution of Target Portfolio as soon as is practicable after the Closing, all upon and subject to the terms and conditions of the Agreement (the “Reorganization”). Capitalized terms not otherwise defined herein shall have the meanings assigned to them in the
