ContractAgreement and Plan of Merger • August 30th, 2024 • Renasant Corp • 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 July 29, 2024 (the “Agreement”), by and between The First Bancshares, Inc., a Mississippi corporation (“First Bancshares”), and Renasant Corporation, a Mississippi corporation (“Renasant”), pursuant to which, at the Effective Time, First Bancshares will merge with and into Renasant, with Renasant as the surviving entity (the “Merger”). This opinion is being delivered in connection with and as an exhibit to the registration statement on Form S-4, including the joint proxy/prospectus included therewith (the “Registration Statement”), filed by Renasant with the Securities and Exchange Commission (the “SEC”). All capitalized terms used but not defined herein shall have the meanings set forth in the Agreement.
