June 22, 2020 BlackRock Muni New York Intermediate Duration Fund, Inc. BlackRock Multi-State Municipal Series Trust Wilmington, Delaware 19809 Ladies and Gentlemen:Agreement and Plan of Merger • July 13th, 2020 • Blackrock Multi State Municipal Series Trust
BlackRock Muni New York Intermediate Duration Fund, Inc., a Maryland corporation (“Target Fund”), BlackRock Multi-State Municipal Series Trust, a Massachusetts business trust (“Trust”), on behalf of its separate series BlackRock New York Municipal Opportunities Fund (“Acquiring Fund”), and New York Municipal Opportunities Fund, LLC, a Massachusetts limited liability company and a direct, wholly-owned subsidiary of the Acquiring Fund (“Merger Sub”), have requested our opinion as to certain federal income tax consequences of the merger of the Target Fund with and into the Merger Sub pursuant to an Agreement and Plan of Merger dated June 1, 2020 (“Plan”). The Plan contemplates (i) the merger under the applicable state laws of the Target Fund with and into the Merger Sub, with the Merger Sub surviving, pursuant to which shares of common stock of the Target Fund will be converted into newly issued shares of beneficial interest of the Acquiring Fund, and (ii) as soon as practicable following
