ContractTax Opinion • August 18th, 2021 • Pacer Funds Trust
Pacific Global ETF Trust 840 Newport Center Drive, 7th Floor Newport Beach, CA 92660 Pacer Funds Trust500 Chesterfield ParkwayMalvern, PA 19355
Northern Lights Fund Trust 17605 Wright Street Omaha, NE 68130Tax Opinion • July 31st, 2020 • Northern Lights Fund Trust
Re: AGREEMENT AND PLAN OF REORGANIZATION, DATED AS OF JULY 31, 2020 (THE "AGREEMENT"), AMONG NORTHERN LIGHTS FUND TRUST (THE "TRUST") on behalf of ITS SERIES, TOEWS TACTICAL GROWTRH ALLOCATION Fund (THE "TARGET FUND") AND TOEWS TACTICAL MONUMENT FUND (THE "SURVIVOR FUND"), AND, SOLELY FOR PURPOSES OF PARAGRAPH 6 THEREOF, TOEWS CORPORATION (THE "ADVISER")
FORM OF TAX OPINION] February __, 1998 German American Bancorp 711 Main Street Box 810 Jasper, Indiana 47546 Subject: Agreement and Plan of Reorganization by and among CSB Bancorp, The Citizens State Bank of Petersburg, German American Bancorp, German...Tax Opinion • February 26th, 1998 • German American Bancorp • State commercial banks
May 2, 1997Tax Opinion • May 21st, 1997 • First Pacific Mutual Fund Inc /Hi/
Re: Form of Tax Opinion, dated as of November 21, 2011 (the “Agreement”), between Rydex Series Funds, a Delaware statutory trust (“RSF”), on behalf of its series, the Multi-Hedge Strategies Fund (the “Acquiring Fund”) and the Alternative Strategies...Tax Opinion • February 1st, 2012 • Rydex Series Funds
You have requested our opinion as to certain U.S. federal income tax consequences of the reorganization of the Acquired Fund and the Acquiring Fund (the “Reorganization”). The Reorganization will involve the transfer of all of the assets of the Acquired Fund to the Acquiring Fund and the assumption of the liabilities of the Acquired Fund by the Acquiring Fund in exchange for shares of beneficial interest of the Acquiring Fund. The shares of the Acquiring Fund will be distributed to the shareholders of the Acquired Fund, following which the Acquired Fund will be liquidated. In the distribution, holders of H-Class Shares, A-Class Shares and C-Class Shares of the Acquired Fund will receive H-Class Shares, A-Class Shares and C-Class Shares, respectively, of the Acquiring Fund.
MSS Series Trust 8000 Town Centre Drive, Suite 400 Broadview Heights, OH 44147 CCA Investments Trust 8000 Town Centre Drive, Suite 400 Broadview Heights, OH 44147Tax Opinion • September 25th, 2017 • MSS Series Trust
AGREEMENT AND PLAN OF REORGANIZATION, DATED AS OF OCTOBER 13, 2017 (THE "AGREEMENT"), BY AND AMONG CCA INVESTMENTS TRUST ("CCA INVESTMENTS TRUST") ON BEHALF OF ITS SERIES, CCA AGGRESSIVE RETURN FUND (THE "EXISTING FUND"), MSS SERIES TRUST (THE "TRUST") ON BEHALF OF ITS SERIES, CCA AGGRESSIVE RETURN FUND (THE "NEW FUND") AND, SOLELY FOR PURPOSES OF PARAGRAPH 6 THEREOF, CHECCHI CAPITAL ADVISERS, LLC (THE "ADVISOR")
USQ Core Real Estate FundTax Opinion • June 17th, 2024 • USQ Core Real Estate Fund
ALPS ETF TrustTax Opinion • March 28th, 2019 • Sprott ETF Trust
FORM OF CRAVATH, SWAINE & MOORE LLP TAX OPINIONTax Opinion • July 24th, 2020 • Fiat Chrysler Automobiles N.V. • Motor vehicles & passenger car bodies
Fiat Chrysler Automobiles N.V. (“FCA”), a Dutch public limited liability company, and Peugeot S.A. (“PSA”), a French société anonyme, have entered into the Combination Agreement, dated as of December 17, 2019 (the “Combination Agreement”), pursuant to which FCA and PSA will effect a cross-border merger of PSA into FCA (the “Combination”). We have acted as your tax counsel in connection with the prospectus included in a registration statement filed with the Securities and Exchange Commission (“SEC”) on Form F-4 (Registration No. [●]) on the date hereof (the “Registration Statement”) in connection with the Combination.
The Tocqueville TrustTax Opinion • October 7th, 2019 • Sprott Funds Trust
Quaker Investment Trust 2500 Weston Road, Suite 101 Weston, FL 33331 Frank Funds 781 Crandon Blvd., Unit 602 Key Biscayne, FL 33149Tax Opinion • March 13th, 2018 • Frank Funds
AGREEMENT AND PLAN OF REORGANIZATION, DATED AS OF _____________, 2018 (THE "AGREEMENT"), AMONG QUAKER INVESTMENT TRUST ("QUAKER INVESTMENT TRUST") ON BEHALF OF ITS SERIES, QUAKER EVENT ARBITRAGE FUND ("EXISTING FUND"), FRANK FUNDS (THE "TRUST") ON BEHALF OF ITS SERIES, CAMELOT EVENT DRIVEN FUND ("NEW FUND") AND, SOLELY FOR PURPOSES OF PARAGRAPH 6 THEREOF, CAMELOT EVENT-DRIVEN ADVISORS, LLC ("ADVISOR") AND CAMELOT PORTFOLIOS, LLC ("CAMELOT")
c/o Northern Lights Fund Trust 4221 North 203rd Street, Suite 100 Elkhorn, NE 68022Tax Opinion • September 23rd, 2020 • Northern Lights Fund Trust
Re: AGREEMENT AND PLAN OF REORGANIZATION AND TERMINATION, DATED AS OF JULY 31, 2020 (THE "AGREEMENT"), AMONG NORTHERN LIGHTS FUND TRUST, a DELAWARE STATURORY TRUST (THE "TRUST") on behalf of ITS SERIES, TOEWS TACTICAL GROWTH ALLOCATION Fund (THE "TRANSFERRING FUND") AND ITS SERIES, TOEWS TACTICAL MONUMENT FUND (THE "ACQUIRING FUND") AND, SOLELY FOR PURPOSES OF PARAGRAPH 6 THEREOF, TOEWS CORPORATION (THE "ADVISER")
ALSTON&BIRD LLPTax Opinion • April 3rd, 2015 • Renasant Corp • State commercial banks
You have requested our opinion regarding certain U.S. federal income tax consequences of the mergers contemplated by the Agreement and Plan of Merger, dated as of December 10, 2014 (the “Plan of Merger”), by and among Renasant Corporation, a Mississippi corporation (“Renasant Holding”), Renasant Bank, a Mississippi banking association and wholly owned subsidiary of Renasant (“Renasant Bank,” and collectively with Renasant Holding, “Renasant”), Heritage Financial Group, Inc., a Maryland corporation (“Heritage Holding”), HeritageBank of the South, a Georgia savings bank (“Heritage Bank,” and collectively with Heritage Holding, “Heritage”). Pursuant to the Plan of Merger, at the Effective Time, Heritage Holding will merge with and into Renasant Holding, with Renasant Holding as the surviving corporation (the “Merger”). Immediately following the Merger, and pursuant to the Plan of Merger, Heritage Bank will merge with and into Renasant Bank, with Renasant Bank as the surviving bank. All ca
FORM OF TAX OPINIONTax Opinion • July 24th, 2020 • Allianz Variable Insurance Products Trust
You have requested our opinion regarding certain federal income tax consequences to the holders ("Contract Owners") of certain variable annuity contracts and variable life insurance policies (collectively, the "Contracts") that are issued or administered by Allianz Life Insurance Company of North America (“Allianz Life”) or by Allianz Life Insurance Company of New York ("Allianz Life of NY") and funded by separate accounts of Allianz Life or Allianz Life of NY for which the Acquired Fund and Acquiring Fund, each a separate series of the Trust, serve as underlying investment vehicles.
EXHIBIT 8Tax Opinion • January 24th, 1997 • Colonial Bancgroup Inc • State commercial banks
AdvisorShares TrustTax Opinion • November 8th, 2019 • Pacific Global ETF Trust
Steben Alternative Investment Funds9711 Washingtonian Boulevard, Suite 400Gaithersburg, MD 20878Tax Opinion • November 8th, 2019 • LoCorr Investment Trust
Re: AGREEMENT AND PLAN OF REORGANIZATION, DATED AS OF NOVEMBER [ ], 2019 (THE "AGREEMENT"), AMONG STEBEN ALTERNATIVE INVESTMENT FUNDS (THE "STEBEN TRUST"), ON BEHALF OF ITS SERIES, STEBEN MANAGED FUTURES STRATEGY FUND (THE "TARGET FUND") AND LOCORR INVESTMENT TRUST (“LOCORR TRUST”), ON BEHALF OF ITS SERIES LOCORR MACRO STRATEGIES FUND (THE "ACQUIRING FUND"), AND, SOLELY FOR PURPOSES OF ARTICLE IX THEREOF, LOCORR FUND MANAGEMENT LLC (THE "ADVISER")
Flat Rock Capital Corp.Tax Opinion • September 2nd, 2020 • Flat Rock Core Income Fund
ContractTax Opinion • June 8th, 2021 • Colony Bankcorp 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 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.
FORM OF TAX OPINION November 20, 1998 Board of Trustees Frank Russell Investment Company 909 A Street Tacoma, Washington 98402 Re: Agreement and Plan of Reorganization made as of November 20, 1998 by Frank Russell Investment Company, a Massachusetts...Tax Opinion • September 18th, 1998 • Russell Frank Investment Co
