FOUR TIMES SQUARESpecial Counsel Engagement • March 20th, 2017 • Guggenheim Enhanced Equity Income Fund (F/K/a Old Mutual/Claymore Long-Short Fund)
We have acted as special counsel to Guggenheim Enhanced Equity Income Fund, a registered diversified closed-end investment company organized as a Delaware statutory trust (the “Acquiring Fund”) and Guggenheim Equal Weight Enhanced Equity Income Fund, a registered diversified closed-end investment company organized as a Delaware statutory trust (the “Target Fund”) in connection with the Agreement and Plan of Merger, dated as of October 5, 2016 (the “Agreement”) between the Acquiring Fund and the Target Fund which, among other things, provides for the merger of the Target Fund with and into the Acquiring Fund, with the Acquiring Fund being the surviving entity and holders of common shares of the Target Fund (the “Target Fund Shares”) receiving, in cancellation of their Target Fund Shares, solely common shares of the Acquiring Fund (collectively, the “Reorganization”). You have requested our opinion regarding whether the Reorganization will be treated for U.S. federal income tax purposes
