October 24, 2008 Precision Drilling Trust 4200, 150-6th Avenue S.W. Calgary, Alberta, Canada T2P 3Y7Precision Drilling Trust • October 27th, 2008 • Drilling oil & gas wells
Re: Agreement and Plan of Merger (the “Merger Agreement”) dated as of August 24, 2008 by and between Precision Drilling Trust, Grey Wolf, Inc., Precision Drilling Corporation and Precision Lobos Corporation
October 24, 2008 Precision Drilling Trust 4200, 150-6th Avenue S.W. Calgary, Alberta, Canada T2P 3Y7 Dear Sirs/Mesdames: Agreement and Plan of Merger, dated August 24, 2008, by and among Grey Wolf, Inc., Precision Drilling Trust, Precision Drilling...Precision Drilling Trust • October 27th, 2008 • Drilling oil & gas wells
We have acted as Canadian tax counsel to Precision Drilling Trust, an Alberta unincorporated open-ended investment trust (“Precision”), in connection with the Registration Statement on Form F-4 (the “Registration Statement”) (Registration No. 333-153664) filed by Precision with the Securities and Exchange Commission (the “Commission”) under the Securities Act of 1933, as amended, relating to the merger (the “Merger”) contemplated by the Agreement and Plan of Merger, dated as of August 24, 2008 (including the exhibits thereto, the “Merger Agreement”) by and among Precision, Grey Wolf, Inc., a Texas corporation (“Grey Wolf”), Precision Drilling Corporation, an Alberta corporation and a direct, wholly-owned subsidiary of Precision (“PDC”), and Precision Lobos Corporation, a Texas corporation and a direct wholly-owned subsidiary of Precision (“Precision Merger Sub”). This opinion is being delivered in connection with the Registration Statement, to which this opinion appears as an exhibit.
