ContractColony Bankcorp Inc • June 8th, 2021 • 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 April 22, 2021, (the “Agreement”), between Colony Bankcorp, Inc., a Georgia corporation (“Colony”), and SouthCrest Financial Group, Inc., a Georgia corporation (“SCSG”), pursuant to which SCSG will merge with and into Colony, with Colony surviving (the “Merger”). We are rendering this opinion in connection with the filing of the Registration Statement on Form S-4 (as may be amended from time to time and including the joint proxy statement/prospectus therein, the “Registration Statement”) with the U.S. Securities and Exchange Commission (the “SEC”). All capitalized terms used but not defined herein shall have the meanings set forth in the Agreement.
