One Atlantic CenterAgreement and Plan of Merger • May 8th, 2017 • Southern National Bancorp of Virginia 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 13, 2016, and as amended effective March 8, 2017 and April 5, 2017 (as amended, the “Agreement”), between Eastern Virginia Bankshares, Inc., a Virginia corporation (“Company”) and Southern National Bancorp of Virginia, Inc., a Virginia corporation (“Acquiror”), pursuant to which, on the terms and conditions set forth therein, Company will merge with and into Acquiror, in accordance with the applicable provisions of the Virginia Stock Corporation Act (the “Merger”). All capitalized terms used but not defined herein shall have the meanings set forth in the Agreement.
