Re: Agreement and Plan of Reorganization, dated as of the date hereof (the “Plan”), by Syntax ETF Trust (the “Trust”), on behalf of (a) the five series of the Trust identified in Schedule A as an Acquired Fund (each, an “Acquired Fund,” and together,...Exchange Listed Funds Trust • May 2nd, 2024
This opinion is furnished to you pursuant to the Plan. You have requested our opinions as to certain U.S. federal income tax consequences of the reorganizations of each Acquired Fund and the corresponding Acquiring Fund that will consist of, pursuant to the Plan: (1) the transfer of all of the assets of the Acquired Fund to the corresponding Acquiring Fund as shown on Schedule A attached hereto in exchange for (i) shares of beneficial interests of such Acquiring Fund (“Acquiring Fund Shares”) and cash in lieu of fractional shares of the Acquiring Fund and (ii) the assumption of the liabilities of the Acquired Fund by the corresponding Acquiring Fund; (2) the distribution of the Acquiring Fund Shares and cash in lieu of fractional shares of the Acquiring Fund to the shareholders of the corresponding Acquired Fund; and (3) followed immediately by the complete liquidation of the Acquired Fund. The transactions described in (1) through (3) of the immediately preceding sentence, collectivel
