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Each year's net revenues will be in an amount sufficient to pay 105% of the interest coming due <br />August 1 in the year of collection, and the principal and interest coming due February 1 of the <br />following year. <br />FUTURE FINANCING <br />The City does not anticipate any additional borrowing for at least the next 90 days. <br />LITIGATION <br />The City is not aware of any threatened or pending litigation affecting the validity of the Bonds or <br />the City's ability to meet its financial obligations. <br />LEGALITY <br />The Bonds are subject to approval as to certain matters by Kennedy & Graven, Chartered, of <br />Minneapolis, Minnesota as Bond Counsel for the City. Bond Counsel has not participated in the <br />preparation of this Official Statement, except for the following "Tax Exemption" section, and will <br />not pass upon its accuracy, completeness, or sufficiency. Bond Counsel has neither examined <br />nor attempted to examine or verify any of the financial or statistical statements, or data <br />contained in this Official Statement, and will express no opinion with respect thereto. Legal <br />opinions in substantially the forms set out as Appendix I to this Official Statement will be <br />delivered at closing. <br />TAX EXEMPTION <br />In the opinion of Bond Counsel, under existing statutes, regulations, rulings and decisions, <br />interest on the Bonds is not includable in the "gross income" of the owners thereof for purposes <br />of federal income taxation and is not includable in taxable net income of individuals, estates or <br />trusts for purposes of State of Minnesota income taxation, but is subject to State of Minnesota <br />franchise taxes measured by income that are imposed upon corporations and financial <br />institutions. <br />Noncompliance following the issuance of the Bonds with certain requirements of the Internal <br />Revenue Code of 1986, as amended, (the "Code ") and covenants of the Bond resolutions may <br />result in the inclusion of interest on the Bonds in gross income (for federal tax purposes) and <br />taxable net income for State of Minnesota tax purposes of the owners thereof. No provision has <br />been made for redemption of the Bonds, or for an increase in the interest rate on the Bonds, in <br />the event that interest on the Bonds becomes subject to United States or State of Minnesota <br />income taxation. <br />The Code imposes an alternative minimum tax with respect to individuals and corporations on <br />alternative minimum taxable income. Interest on the Bonds will not be treated as a preference <br />item in calculating alternative minimum taxable income. The Code provides, however, that a <br />portion of the adjusted current earnings of a corporation not otherwise included in the minimum <br />- 6 - <br />