Re: Form of Tax Opinion, dated as of November 21, 2011 (the “Agreement”), between Rydex Series Funds, a Delaware statutory trust (“RSF”), on behalf of its series, the Multi-Hedge Strategies Fund (the “Acquiring Fund”) and the Alternative Strategies...Rydex Series Funds • February 1st, 2012
You have requested our opinion as to certain U.S. federal income tax consequences of the reorganization of the Acquired Fund and the Acquiring Fund (the “Reorganization”). The Reorganization will involve the transfer of all of the assets of the Acquired Fund to the Acquiring Fund and the assumption of the liabilities of the Acquired Fund by the Acquiring Fund in exchange for shares of beneficial interest of the Acquiring Fund. The shares of the Acquiring Fund will be distributed to the shareholders of the Acquired Fund, following which the Acquired Fund will be liquidated. In the distribution, holders of H-Class Shares, A-Class Shares and C-Class Shares of the Acquired Fund will receive H-Class Shares, A-Class Shares and C-Class Shares, respectively, of the Acquiring Fund.
