One Atlantic CenterAgreement and Plan of Merger • February 28th, 2020 • Business First Bancshares, 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 January 22, 2020 (the “Agreement”), by and between Business First Bancshares, Inc., a Louisiana corporation (“BFST”), and Pedestal Bancshares, Inc., a Louisiana corporation (“PBI”), pursuant to which, at the Effective Time, PBI will merge with and into BFST, with BFST as the surviving entity (the “Merger”). All capitalized terms used but not defined herein shall have the meanings set forth in the Agreement. This opinion is being delivered in connection with the amended registration statement on Form S-4 of BFST (the “Registration Statement”), filed by BFST with the Securities and Exchange Commission (the “SEC”) under the Securities Act of 1933, as amended, on February 28, 2020, and to which this opinion is an exhibit.
