Re: Agreement and Plan of Redomestication (“Agreement”) made as of the 2nd day of July, 2012 by and among (i) each of the Invesco closed-end registered investment companies identified as a Predecessor Fund on Exhibit A hereto (each a “Predecessor...Agreement and Plan of Redomestication • May 1st, 2013 • Invesco Value Municipal Income Trust
You have requested our opinion concerning certain federal income tax consequences of the reorganization of each Predecessor Fund pursuant to which: (i) the transfer of all of the assets of a Predecessor Fund to the Successor Fund in exchange for the issuance by the Successor Fund to the Predecessor Fund of shares of beneficial interest of the Successor Fund (“Successor Fund Shares”), which are voting securities, (ii) the assumption by the Successor Fund of all liabilities of the Predecessor Fund, (iii) the distribution of the shares of beneficial interest of the Successor Fund to the holders of shares of beneficial interest of the Predecessor Fund (“Predecessor Fund Shares”) according to their respective interests in complete liquidation of the Predecessor Fund; and (iv) the dissolution of the Predecessor Fund as soon as practicable after the Closing (each such transaction, a “Reorganization” and collectively, the “Reorganizations”), all upon and subject to the terms and conditions of
Re: Agreement and Plan of Redomestication (“Agreement”) made as of the 2nd day of July, 2012 by and among (i) each of the Invesco closed-end registered investment companies identified as a Predecessor Fund on Exhibit A hereto (each a “Predecessor...Agreement and Plan of Redomestication • May 1st, 2013 • Invesco California Value Municipal Income Trust
In rendering our opinion, we have reviewed and relied upon: (a) a copy of the executed Agreement, dated as of July 2, 2012; (b) the combined proxy statement/prospectus and, if applicable, the Schedule 14A proxy statement provided to shareholders of each Predecessor Fund in connection with a Special Meeting of Shareholders of each Predecessor Fund held on July 17, 2012, adjourned until August 14, 2012; (c) certain representations concerning the Reorganizations made to us by each Predecessor Fund and each Successor Fund in a letter dated August 27, 2012 (the “Representation Letter”); (d) all other documents, financial and other reports and corporate minutes we deemed relevant or appropriate; and (f) such statutes, regulations, rulings and decisions as we
AGREEMENT AND PLAN OF REDOMESTICATION THIS AGREEMENT AND PLAN OF REDOMESTICATION ("Agreement") is adopted as of this 13th day of April, 2017 by and between RMR Real Estate Income Fund, a Delaware statutory trust and a registered closed-end investment...Agreement and Plan of Redomestication • August 25th, 2017 • RMR Real Estate Income Fund • Maryland
