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C. WHEREAS, the Issuer covenanted to take such actions <br />as are necessary to effectuate such attempted designation; and <br />D. WHEREAS, for the Bonds to get the benefit of being <br />designated as "qualified tax - exempt obligations" under Section <br />265(b)(3) of the federal Internal Revenue Code of 1986, as <br />amended (the "Code "), it is necessary that the Issuer <br />designate the Bonds pursuant to subparagraph (B) of Section <br />1009(b)(3) of the federal Technical and Miscellaneous Revenue <br />Act of 1988 ( "TAMRA ") and Section 255(b)(3) of the Code; and <br />E. WHEREAS, the Bonds qualify for such designation <br />because they are not private activity bonds (or, if private <br />activity bonds, are qualified 501(c)(3) bonds, or refund bonds <br />which were not industrial development bonds or private loan <br />bonds), the Issuer with respect to bonds issued in 1986 is a <br />"qualified small issuer" of $10,000,000 or less of bonds, and <br />not more than $10,000,000 of bonds issued in 1986 have been <br />designated: <br />NOW, THEREFORE, BE IT RESOLVED by the Council of the City <br />of Little Canada, Minnesota, as follows: <br />1. Designation of Qualified Tax - Exempt Obligations. In <br />order to qualify the Bonds as "qualified tax - exempt <br />obligations" within the meaning of Section 265(b)(3) of the <br />Code, the Issuer hereby makes the following factual statements <br />and representations: <br />(a) the Bonds were issued after August 7, 1986; <br />(b) the Bonds are not "private activity bonds" as <br />defined in Section 141 of the Code, or, if private activity <br />bonds, they are: <br />(i) qualified 501(c)(3) bonds as defined in <br />Section 145 of the Code, or <br />(ii) obligations issued to refund (or which <br />are part of a series of obligations issued to <br />refund) obligations issued before August 8, 1986, <br />which were not industrial development bonds (as <br />defined in Section 103(b)(2) of the federal Internal <br />Revenue Code of 1954, as amended, as in effect on <br />the day before the date of the enactment of the <br />federal Tax Reform Act of 1986) or a private loan <br />bond (as defined in Section 103(o)(2)(A) as so in <br />effect, but without regard to any exemption from <br />such definition other than Section 103(o)(2)(A)); <br />2 <br />Page 10 <br />