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DoRSEY & WHITNEY <br /> $525,000 General Obligation City of St. Anthony, Hennepin, <br /> Improvement Bonds, Series 1994A and Ramsey Counties, Minnesota <br /> -2- <br /> (c) is not an item of tax preference includable in alternative minimum taxable <br /> income for purposes of the federal alternative minimum tax applicable to all <br /> taxpayers or the Minnesota alternative minimum tax applicable to individuals, <br /> estates and trusts; and (d) is includable in adjusted current earnings of corporations <br /> in determining alternative minimum taxable income for purposes of the federal <br /> alternative minimum tax imposed on corporations. <br /> 4. The City has designated the Bonds as "qualified tax-exempt <br /> obligations" within the meaning of Section 265(b)(3) of the Internal Revenue Code <br /> of 1986, as amended (the "Code"), and, financial institutions described in Section <br /> 265(b)(5) of the Code may treat the Bonds for purposes of Section 265(b)(2) and <br /> 291(e)(1)(B) of the Code as if they were acquired on August 7, 1986. <br /> The opinions expressed in paragraphs 1 and 2 are subject as to <br /> enforceability to the effect of any state or federal laws relating to bankruptcy, <br /> insolvency, reorganization, moratorium or creditors' rights and the exercise of <br /> judicial discretion. <br /> The opinions set forth in paragraphs 3 and 4 are subject to the <br /> condition that the City comply with all the requirements of the Code that must be <br /> satisfied subsequent to the issuance of the Bonds in order that interest thereon be, or <br /> continue to be, excluded from gross income for federal income tax purposes, and the <br /> Bonds be and continue to be qualified tax-exempt obligations. The City has <br /> covenanted in the resolution authorizing the issuance of the Bonds to comply with <br /> these continuing requirements. Failure of the City to comply with these <br /> requirements may result in the inclusion of interest on the Bonds in federal gross <br /> income and in Minnesota taxable net income, retroactive to the date of issuance of <br /> the Bonds. Except as stated in this opinion, we express no opinion regarding federal, <br /> state or other tax consequences to owners of the Bonds. <br /> We have not been asked, and have not undertaken, to review the <br /> accuracy, completeness or sufficiency of any offering materials relating to the Bonds, <br /> and accordingly, we express no opinion with respect thereto. <br /> Dated: June , 1994. <br /> Very truly yours, <br />