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<br />- 8 - <br />For example, legislation has been proposed that effectively would impose a partial tax on otherwise tax- <br />exempt interest for certain higher income taxpayers. The likelihood of adoption of this or any other such <br />legislative proposal relating to tax-exempt bonds cannot be reliably predicted. If enacted into law, current <br />or future proposals may have a prospective or retroactive effect and could affect the value or marketability <br />of tax-exempt bonds (including the Bonds). Prospective purchasers of the Bonds should consult their own <br />tax advisors regarding the impact of any such change in law. <br /> <br />The above is not a comprehensive list of all federal tax consequences which may arise from the receipt of <br />interest on the Bonds. The receipt of interest on the Bonds may otherwise affect the federal or state income <br />tax liability of the recipient based on the particular taxes to which the recipient is subject and the particular <br />tax status of other items or deductions. Bond Counsel expresses no opinion regarding any such <br />consequences. All prospective purchasers of the Bonds are encouraged to consult with their personal tax <br />advisors as to the tax consequences of, or tax considerations for, purchasing or holding the Bonds. <br /> <br /> <br /> <br />BANK-QUALIFIED TAX-EXEMPT OBLIGATIONS <br />The City will designate the Bonds as “qualified tax-exempt obligations” for purposes of Section 265(b)(3) <br />of the Code, relating to the ability of financial institutions to deduct from income for federal income tax <br />purposes, interest expense that is allocable to carrying and acquiring tax-exempt obligations. <br /> <br /> <br /> <br />RATING <br />Application for a rating of the Bonds has been made to S&P Global Ratings (“S&P”), 55 Water Street, New <br />York, New York. If a rating is assigned, it will reflect only the opinion of S&P. Any explanation of the <br />significance of the rating may be obtained only from S&P. <br /> <br />There is no assurance that a rating, if assigned, will continue for any given period of time, or that such <br />rating will not be revised, suspended or withdrawn, if, in the judgment of S&P, circumstances so warrant. <br />A revision, suspension or withdrawal of a rating may have an adverse effect on the market price of the <br />Bonds. <br /> <br /> <br /> <br />MUNICIPAL ADVISOR <br />The City has retained Springsted Incorporated, Public Sector Advisors, of Saint Paul, Minnesota <br />(“Springsted”), as municipal advisor in connection with certain aspects of the issuance of the Bonds. In <br />preparing this Official Statement, Springsted has relied upon governmental officials, and other sources, <br />who have access to relevant data to provide accurate information for this Official Statement, and Springsted <br />has not been engaged, nor has it undertaken, to independently verify the accuracy of such information. <br />Springsted is not a public accounting firm and has not been engaged by the City to compile, review, examine <br />or audit any information in this Official Statement in accordance with accounting standards. Springsted is <br />an independent advisory firm, registered as a municipal advisor, and is not engaged in the business of <br />underwriting, trading or distributing municipal securities or other public securities. <br /> <br />Springsted is under common ownership with Springsted Investment Advisors, Inc. (“SIA”), an investment <br />adviser registered in the states where services are provided. SIA may provide investment advisory services <br />to the City from time to time in connection with the investment of proceeds from the Bonds as well as <br />advice with respect to portfolio management and investment policies for the City. SIA pays Springsted, as <br />municipal advisor, a referral fee from the fees paid to SIA by the City.