Res 1988-007 - Laserfiche WebLink

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interest on the Bonds will be included in the "adjusted net book income" or the "adjusted current earnings" of certain corporations for purposes of computing the alternative minimum tax and the environmental tax imposed on such corporations. Furthermore, in the opinion of Bond Counsel, interest on the Bonds wi1l be excludable from gross income under Section 103(a) of the Code. The statutes, applicable regulations, published rulings of the Internal Revenue Service and court decisions on which such opinions are based are subject to change. These opinions are dependent in part on future compliance by the City with certain post-issuance requirements of the Code, including the arbitrage rebate requirements. Failure to comply with such requirements may cause the interest on the Bonds to be includable in gross income retroactive to the date of issue. In this connection, various covenants and representations have been made by the City in the documents authorizing the issuance of the Bonds that are designed to provide assurance of compliance with such requirements, and for purposes of these opinions, we assume compUance by the City therewith. In addition such opinions are based upon representations and certifications of the City pertaining to the use, expenditure and investment of the proceeds of the Bonds. Except as described above, we express no opinion with respect to any other federal, state or local tax consequences under present law or proposed legislation resulting from the receipt or accrual of interest on, or the acquisition, ownership or disposition of, the Bonds. Prospective purchasers of the Bonds should be aware that the ownership of tax-exempt obligations such as the Bonds may result in collateral federal tax consequences to, among others, financial institutions, property and casualty insurance companies, certain foreign corporations doing business in the United States, individual recipients of Social Security or Railroad Retirement benefits, taxpayers who may be deemed to have incurred or continued indebtedness to purchase or carry tax-exempt obligations, stockholders of corporations receiving or accruing tax exempt interest and S corporations with Subchapter C earnings and profits. Prospective purchasers should consult their own tax advisors as to the applicabili ty of these and other such collateral consequences to their particular circumstances. THE OPINIONS CONTAINED HEREIN are limited to the extent that the rights of the registered owners of the Bonds and the enforceability thereof may be subject to bankruptcy, insolvency, reorganization, moratorium and other similar laws affecting creditorst rights or remedies generally and to the extent that certain equitable remedies, including specific peñormance, may be unavailable. WE HAVE ACTED AS COUNSEL for the City for the sole purpose of rendering an opinion with respect to the legality and validity of the Bonds under the Constitution and laws of the State of Texas and with respect to the application to the Bonds of those provisions of the Code as to which an opinion is rendered herein and for no other reason or purpose. We have not been requested to investigate or verify and have not independently investigated or verified any records, data or other -2-