Laserfiche WebLink
4905-5558-6638.1 <br />June 30, 2025 <br /> <br /> <br />Minnesota Management and Budget <br />Treasury Division <br />400 Centennial Building <br />658 Cedar Street <br />St. Paul, Minnesota 55155-1489 <br /> <br />RE: City of Little Canada, Minnesota <br />Multifamily Housing Revenue Bonds (Little Canada Senior Housing Project) <br /> <br />We are acting as bond counsel to the City of Little Canada, Minnesota in connection with the issuance <br />of the above-referenced obligations (the “Bonds”). We have reviewed an Application for Allocation of Bonding <br />Authority for Residential Rental Projects, Form H-Rental (Revised December 2020) with respect to the Bonds. <br />We are of the opinion that the proposed Bonds require an allocation of bonding authority under Minnesota <br />Statutes, Chapter 474A, as amended (the “Allocation Act”), and Section 146 of the Internal Revenue Code of <br />1986, as amended (the “Code”), in the amount requested, that the Bonds, when issued, will constitute <br />“residential rental project bonds,” to be issued to finance a “qualified residential rental project” within the <br />meaning of the Allocation Act, and that the Bonds will finance a “qualified residential rental project” within <br />the meaning of Section 142(d) of the Code and a “multifamily housing development” within the meaning of <br />Minnesota Statutes, Section 462C, as amended. The project does not preserve existing federally subsidized <br />housing. <br />TAFT STETTINIUS & HOLLISTER LLP <br /> <br />By: