JAMES ● BATES ● BRANNAN ● GROOVER LLP WILLARD D. THOMPSON EMAIL: wthompson@jamesbatesllp.com DIRECT LINE: 478-749-9903Agreement and Plan of Merger • February 11th, 2019 • Colony Bankcorp Inc • State 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 December 17, 2018 (the “Agreement”) between Colony Bankcorp, Inc., a Georgia corporation (“CBAN”), and LBC Bancshares, Inc., a Georgia corporation (“LBC”), pursuant to which, at the Effective Time, LBC will merge with and into CBAN, with CBAN as the surviving corporation (the “Merger”). All capitalized terms used but not defined herein shall have the meanings set forth in the Agreement.
