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General <br /> The preceding is not a comprehensive list of all federal tax consequences which may arise from the re- <br /> ceipt or accrual of interest on the Bonds. The receipt or accrual of interest on the Bonds may otherwise <br /> affect the federal income tax (or Minnesota income tax or franchise tax) liability of the recipient based <br /> on the particular taxes to which the recipient is subject and the particular tax status of other items of in- <br /> come or deductions. All prospective purchasers of the Bonds are advised to consult their own tax advi- <br /> sors as to the tax consequences of, or tax considerations for, purchasing or holding the Bonds. <br /> Qualified Tax - Exempt Obligations <br /> • <br /> The City will designate the Bonds as "qualified tax- exempt obligations" for purposes of Section <br /> 265(b)(3) of the Code relating to the ability of financial institutions to deduct from income for federal <br /> income tax purposes, interest expense that is allocable to carrying and acquiring tax- exempt obliga- 1 <br /> tions. "Qualified tax- exempt obligations" are treated as acquired by a financial institution before <br /> August 8, 1986. Interest allocable to such obligations remains subject to the 20% disallowance under <br /> prior law. <br /> -16- <br />