Common Contracts

4 similar null contracts by Columbia Funds Series Trust, Columbia Funds Series Trust I

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Columbia Funds Series Trust • March 3rd, 2022

The Reorganizations will be accomplished pursuant to an Agreement and Plan of Reorganization, dated as of October 5, 2021, entered into by the Acquiring Company, on behalf of the Acquiring Funds, and the Target Company, on behalf of the Target Funds, and for purposes of paragraphs 6.8, 10.2, 12.2 and 15 thereof only, BMO Asset Management Corp, and for purposes of paragraphs 10.2, 12.2 and 15 thereof only, Columbia Management Investment Advisers, LLC (the “Plan”). Each Reorganization contemplates the transfer of all the assets of the Target Fund to its corresponding Acquiring Fund as set forth on Schedule A solely in exchange for voting common shares of beneficial interest (“Acquisition Shares”) of the corresponding Acquiring Fund and the assumption by the corresponding Acquiring Fund of all the Obligations (as defined in the Plan) of the Target Fund. As part of each Reorganization, the Target Fund will immediately thereafter distribute pro rata, by class, to its shareholders of record

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Columbia Funds Series Trust I • March 3rd, 2022

The Reorganizations will be accomplished pursuant to an Agreement and Plan of Reorganization, dated as of October 5, 2021, entered into by the Acquiring Company, on behalf of the Acquiring Funds, and the Target Company, on behalf of the Target Funds, and for purposes of paragraphs 6.8, 10.2, 12.2 and 15 thereof only, BMO Asset Management Corp. and for purposes of paragraphs 10.2, 12.2 and 15 thereof only, Columbia Management Investment Advisers, LLC (the “Plan”). Each Reorganization contemplates the transfer of all the assets of the Target Fund to its corresponding Acquiring Fund as set forth on Schedule A solely in exchange for voting common shares of beneficial interest (“Acquisition Shares”) of the corresponding Acquiring Fund and the assumption by the corresponding Acquiring Fund of all the Obligations (as defined in the Plan) of the Target Fund. As part of each Reorganization, the Target Fund will immediately thereafter distribute pro rata, by class, to its shareholders of record

Chicago New York Washington, DC London San Francisco Los Angeles Singapore Dallas vedderprice.com
Columbia Funds Series Trust I • March 3rd, 2022

The Reorganizations will be accomplished pursuant to an Agreement and Plan of Reorganization, dated as of October 5, 2021, entered into by the Acquiring Company, on behalf of the Acquiring Funds, and the Target Company, on behalf of the Target Funds, and for purposes of paragraphs 6.8, 10.2, 12.2 and 15 thereof only, BMO Asset Management Corp. and for purposes of paragraphs 10.2, 12.2 and 15 thereof only, Columbia Management Investment Advisers, LLC (the “Plan”). Each Reorganization contemplates the transfer of all the assets of the Target Fund to its corresponding Acquiring Fund as set forth on Schedule A solely in exchange for voting common shares of beneficial interest (“Acquisition Shares”) of the corresponding Acquiring Fund and the assumption by the corresponding Acquiring Fund of all the Obligations (as defined in the Plan) of the Target Fund. As part of each Reorganization, the Target Fund will immediately thereafter distribute pro rata, by class, to its shareholders of record

Contract
Columbia Funds Series Trust • March 3rd, 2022

January 21, 2022 Columbia Funds Series Trust Columbia Funds Series Trust II 290 Congress street 290 Congress Street Boston, Massachusetts 0221 0 Boston, Massachusetts 02210 BMO Funds, Inc. 790 North Water Street, Suite 1100 Milwaukee, Wisconsin 53202 Ladies and Gentlemen: Columbia Fund Series Trust, a Delaware statutory trust, and Columbia Funds Series Trust II, a Massachusetts business trust (each an “Acquiring Company” and collectively, the “Acquiring Companies”), on behalf of each of its series listed on Schedule A attached hereto and incorporated herein by reference,1 and BMO Funds, Inc., a Wisconsin corporation (the “Target Company” and together with the Acquiring Companies, each a “Company” and collectively, the “Companies”), on behalf of each of its series listed on Schedule A, have requested our opinion regarding certain federal income tax consequences of the reorganization (each a “Reorganization” and collectively, the ‘‘Reorganizations”) of each Target Fund listed

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