1987-144 - Laserfiche WebLink

Home Browse Search

TAX EXEMPTION In the opinion of Rhoads S, Sinon, Boca Raton, Florida, Bond Counsel, assuming continuing compliance by the County with certain covenants to caspamended, mly with pin order st fpreserve the ethe l Revenue Code of 1986, on the federal income tax exemption of the interest federalincometaxes interest on the Notes is exempt from and decisions; provided, under existing statutes, regulationsorations to however, that such exemption shall not extend to corp the extent that they are required to include such es imposed the calculation and payment of alternative minimum taxes orpto the under the Internal RevenueCodto ince of iude such inte86, as rest in the extent that they are required Tax" under calculation and payment of the ,Environmentaslamended. Section 59A of the Internal Revenue Code of 1986, exempt from except as to The Notes and the income thereon are taxation under the laws of the by te of Chapter1220,aFlorida Statutes, estate taxes and taxes imposed bydebt on interest, income or profits an associationstions owned by corporations, banks, and saving The County will issue its cert sfand tcircumstances e to the cin that on the basis of the facts, of the Notes, it is not existence on the date of deliverybe expected that proceeds of the Notes gelbonds"sunder Sectionra8ha 'arbitrage as amended, would cause the Notes to be regulations relating 103(b)(2) of the Internal Revenue Code of 1reg in an contemplated by the Unite States Tree certificate be accompanied to "arbitrage bonds"• based upon the facts, estimates and opinion of Bond Counsel, forsaid certificate, that the Notes are circumstances sein e bonds," under existing statutes, t th not currently "arbitrag regulations and decisions. Federal Alternative Minimum Tax Calculations interest be treated as a tax preference item Under the Internal Revenue Code of 198 . received on the Notes maybe to a federal anotrbetive includibleminimum intax includible in income subjec h interest may on corporations althoughof the calculation of regular federal gross income for purposes the federal alternative liability. In addition, ears beginning income tax corporation for tax y minimum taxable income of a of the in 1987 and thereafter is, undaajUetednnetnbookeincome" o f o 1and local 986, based in part upon the which may include interest ra state irrespective of corporation, ations held by the corporation, government oblig although such interest may not when such obligations were issued, 29