Laserfiche WebLink
OF COLLATERAL TAX CONSEQUENCES ARISING FROM RECEIPT OF INTEREST <br /> ON THE SERIES 2001 BONDS. PROSPECTIVE PURCHASERS OR BONDHOLDERS <br /> SHOULD CONSULT THEIR TAX ADVISORS WITH RESPECT TO COLLATERAL <br /> TAX CONSEQUENCES, INCLUDING, WITHOUT LIMITATION, THE <br /> DETERMINATION OF GAIN OR LOSS ON THE SALE OF A SERIES 2001 BOND,THE <br /> CALCULATIONS OF ALTERNATIVE MINIMUM TAX LIABILITY,THE INCLUSION <br /> OF SOCIAL SECURITY OR OTHER RETIREMENT PAYMENTS IN TAXABLE <br /> INCOME, THE DISALLOWANCE OF DEDUCTIONS FOR CERTAIN EXPENSES <br /> ATTRIBUTABLE TO THE SERIES 2001 BONDS AND THE STATE AND LOCAL TAX <br /> RULES IN STATES OTHER THAN MINNESOTA. <br /> Bank Qualified Obligations <br /> The City has designated the Series 2001A Bonds and the Subordinate Bonds as <br /> "qualified tax-exempt obligations" for purposes of Section 265(b)(3) of the Code, relating <br /> to the ability of financial institutions to deduct from income for federal income tax purposes, <br /> interest expense that is allocable to carrying and acquiring tax-exempt obligations. <br /> Tax Considerations for Series 2001B Bonds <br /> In the opinion of Faegre & Benson LLP, as Bond Counsel, interest on the Series <br /> 2001B Bonds is subject to federal and state income taxation. This Official Statement does <br /> not purport to discuss the tax consequences of the purchase, ownership or sale of the Series <br /> 2001B Bonds. Purchasers of the Series 2001B Bonds are urged to consult with their tax <br /> advisors as to the tax consequences pertaining to the Series 2001B Bonds, such as the <br /> consequences of a sale,transfer,redemption or other disposition of the Series 2001 B Bonds <br /> prior to stated maturity, and as to other applications of federal, state, local or foreign tax <br /> laws. <br /> LEGAL MATTERS <br /> The validity of the Series 2001 Bonds,the tax-exempt status of interest of the Series <br /> 2001 Tax-Exempt Bonds and certain other matters will be passed upon by Faegre&Benson <br /> LLP,of Minneapolis,Minnesota,as Bond Counsel. Certain legal matters will be passed on <br /> for the Borrower and the Sponsor by their counsel, Christoffel & Elliott, P.A., in St. Paul, <br /> Minnesota. The Underwriter has been represented in connection with the issuance of the <br /> Series 2001 Bonds by Best& Flanagan LLP. <br /> RELATIONSHIPS AMONG THE PARTIES <br /> In connection with the issuance of the Series 2001 Bonds, the Borrower and the <br /> Underwriter are being represented by the attorneys or law firms identified above under the <br /> heading"LEGAL MATTERS." In other transactions not related to the Series 2001 Bonds, <br />