CC PACKET 07131993 - Laserfiche WebLink

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DORSEY & WHITNEY participating municipalities based on measured volume of use. The City is responsible for the construction and maintenance of sewer laterals. $470,000 General Obligation City of St. Anthony, Hennepin, Protective services are provided by the City through 12 police officers and seven full-time and Improvement Bonds, Series 1993A- and Ramsey Counties, Minnesota 23 volunteer fire fighters. The City owns and operates three municipal liquor stores: one with both on- and off-sale, one off-sale warehouse, and one on-sale store. The Liquor Fund transferred $165,000 to the General Fund in 1992 and $146,500 in 1991. (c) is not an item of tax preference includable in alternati ve minimum taxable income for.purposes of the federal alternative minimum tax applicable to all Employee Pensions taxpayers or the Minnesota alternative minimum tax applicable to individuals, estates and trusts; and (d) is includable in adjusted current earnings of corporations All full-time and certain part-time employees of the City of St. Anthony are covered by defined in determining alternative minimum taxable income for purposes of the federal benefit pension plans administered by the Public Employees Retirement Association of g P Minnesota (PERA). The PERA administers the Public Employees Retirement Fund (PERF) and alternative minimum tax imposed on corporations. the Public Employees Police and Fire Fund (PEPFF) which are cost-sharing multiple-employer public employee retirement plans. PERF members belong to either the Coordinated Plan or 4. The City has designated the Bonds as "qualified tax-exempt the Basic Plan. Coordinated members are covered by Social Security and Basic members are obligations" within the meaning of Section 265(b)(3) of the Internal Revenue Code not. All new members must participate in the Coordinated Plan. All police officers, fire fighters of 1986, as amended (the "Code"), and, financial institutions described in Section and peace officers who qualify for membership by statute are covered by the PEPFF. The 265(b)(5) of the Code may treat the Bonds for purposes of Section 265(b)(2) and City's contribution for employees covered by PERA for the year ended December 31, 1992 was Y pure $151,752, as compared to a contribution of$141,937 in 1991. 291(e)(1)(B) of the Code as if they were acquired on August 7, 1986. The St. Anthony Firefighters Relief Association is the administrator of a single employer The opinions expressed in paragraphs 1 and 2 are subject as to retirement system established to provide pension and other benefits to its membership in enforceability to the effect of any state or federal laws relating to bankruptcy, accordance with Minnesota Statutes. The Association maintains a separate Special Fund to insolvency, reorganization, moratorium or creditors' rights and the exercise of accumulate assets to fund the retirement benefits earned by its membership. Funding of the Association is derived primarily from an insurance premium tax in accordance with the judicial discretion. Volunteer Firefighter's Relief Association Financing Guidelines Act of 1971. As of December 31, 1992, assets of the Special Fund totaled approximately $252,379 (market value The opinions set forth in paragraphs 3 and 4 are subject to the of approximately $255,890) and the liability for pension benefits was estimated at $302,400. condition that the City comply with all the requirements of the Code that must be satisfied subsequent to the issuance of the Bonds in order that interest thereon be, or continue to be, excluded from gross income for federal income tax purposes, and the Bonds be and continue to be qualified tax-exempt obligations. The City has covenanted in the resolution authorizing the issuance of the Bonds to comply with these continuing requirements. Failure of the City to comply with these requirements may result in the inclusion of interest on the Bonds in federal gross income and in Minnesota taxable net income, retroactive to the date of issuance of the Bonds. Except as stated in this opinion, we express no opinion regarding federal, state or other tax consequences to owners of the Bonds. f We have not been asked, and have not undertaken, to review the accuracy, completeness or sufficiency of any offering materials relating to the Bonds, and accordingly, we express no opinion with respect thereto. Dated: 1993. Very truly yours, 1-2