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89-005 RES . . . RESOLUTION 89 - 5 A RESOLUTION FOR THE CITY OF ELK RIVER A RESOLUTION DESIGNATING CERTAIN BONDS ISSUED IN 1986 AS "QUALIFIED TAX-EXEMPT OBLIGATIONS" A. WHEREAS, the City of Elk River, Minnesota (the "Issuer"), issued its $1,975,000 General Obligation Improvement Bonds August 28, 1986, (the "Bonds") after August 7, 1986, the effective date of the federal Tax Reform Act of 1986; and B. WHEREAS, when the Bonds were issued, the Issuer made a designation that it intended to qualify under Section 802 (e) (3) of H.R. 3838 of the 99th Congress as passed by the House of Representatives; and C. WHEREAS, for the Bonds to get the benefit of being designated as "qualified tax-exempt obligations" under Section 265(b} (3) of the federal Internal Revenue Code of 1986, as amended (the "Code"), it is necessary that the Issuer designate the Bonds pursuant to subparagraph (B) of Section 1009(b} (3) of the federal Technical and Miscellaneous Revenue Act of 1988 ("Tamra") and Section 265(b} (3) of the Code; and D. WHEREAS, the Bonds qualify for such designation because they are not private activity bonds (or, if private activitiy bonds, are qualified 501(c) (3) bonds, or refund bonds which were not industrial development bonds or private loan bonds}, the Issuer with respect to bonds issued in 1986 is a "qualified small issuer" of $10,000,000 or less of bonds, and not more than $10,000,000 of bonds issued in 1986 have been designated: NOW, THEREFORE, BE IT RESOLVED by the City Council of the City of Elk River, Minnesota, as follows: 1. Designation of Qualified Tax-Exempt Obliqations. In order to qualify the Bonds as "qualified tax-exempt obligations" within the meaning of Section 265(b} (3) of the Code, the Issuer hereby makes the following factual statements and representations: (a) the Bonds were issued after August 7, 1986: (b) the Bonds are not "private activity bonds" as defined in Section 141 of the Code, or, if private activity bonds, they are: (i) qualified 501(c} (3) bonds as defined in Section 145 of of the Code, or . . . Resolution (continued) Page Two (ii) obligations issued to refund (or which are part of a series of obligations issued to refund) obligations issued before August 8, 1986, which were not industrial development bonds (as defined in Section 103(b) (2) of the federal Internal Revenue Code of 1954, as amended, as in effect on the day before the date of enactment of the federal Tax Reform Act of 1986) or a private loan bond (as defined in Section 103(0) (2) (A) as so in effect, but without regard to any exemption from such definition other than Section 103 (0) (2) (A)); (c) the Issuer hereby designates the Bonds as "qualified tax-exempt obligations" for purposes of Section 265(b) (3) of the Code; (d) the amount of tax-exempt obligations (other than private activity bonds, treating qualified 501(c) (3) bonds as not being private activity bonds) which were issued in 1986 by the Issuer (and all entities treated as one issuer with the Issuer, and all subordinate entities thereof) during calendar year 1986 did not exceed $10,000,000; and (e) not more than $10,000,000 of obligations issued by the Issuer during calendar year 1986 have been designated for purposes of Section 265(b) (3) of the Code. 2. Notice. Notice of the above designation shall be communicated to the United States Department of the Treasury or the United States Internal Revenue Service if and as may be required to give it effect. Passed and adopted this 9th day of January, 1989, by the Elk River City Council. J-------- /? /7 ,J~~ Il .t~-~ James A. Tralle, Mayor ATTEST: a/j?~ Patrick D. Klaers, City Administrator