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1990-03-07 Minutes
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1990-03-07 Minutes
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amount by which "adjusted net book income" exceeds the corporation's "alternative minimum <br />taxable income." After 1989, such alternative minimum taxable income will include 75% of the <br />amount by which "adjusted current earnings" exceed "alternative minimum taxable income." <br />Interest on a Bond would be includable in the "adjusted net book income" and "adjusted <br />current earnings" of a corporation for purposes of such alternative minimum tax. In addition, <br />the Code imposes an environmental tax on corporations for the years beginning after 1986 and <br />before 1992 equal to 0.12°~ of the excess of "modified alternative minimum taxable income" <br />over a specified amount, generally $2 million. Interest on a Bond would be taken into account <br />in computing such environmental tax. Further, the Code imposes a branch profits tax on U.S. <br />branches of foreign corporations equal to 30°~ of the adjusted earnings and profits of such <br />corporations attributable to income that is effectively connected, or treated as such, with the <br />conduct of trade or business in the United States. Interest on the Bonds would be includable <br />in such earnings and profits. <br />Under the Code, ownership of tax-exempt obligations may also result in collateral federal <br />income tax consequences to certain taxpayers including, without limitation, S corporations, <br />financial institutions, property and casualty insurance companies, individual recipients of Social <br />Security or Railroad Retirement benefits and taxpayers who may be deemed to have incurred <br />(or continued) indebtedness to purchase or carry tax-exempt obligations. <br />No provision has been made for redemption of the Bonds, or for an increase in the interest rate <br />on the Bonds, in the event that interest on the Bonds becomes subject to income taxation. <br />The foregoing does not purport to be a comprehensive discussion of the tax consequences of <br />owning the Bonds. Prospective owners of the Bonds should consult their own tax advisors <br />with respect to the foregoing and other tax consequences of owning the Bonds. <br />Not Qualified Tax-Exempt Obligations • <br />The Bonds will not be designated "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 <br />federal income tax purposes, interest expense that is allocable to carrying and acquiring tax- <br />exempt obligations. <br />Financial Advisor <br />Springsted Incorporated, Indianapolis, Indiana, has served as Financial Advisor to the Authority <br />in connection with the issuance of the Bonds. The Financial Advisor will not participate in the <br />underwriting of the Bonds. <br />Certification <br />On March 2, 1990 the Authority adopted this Official Statement. The Authority has authorized <br />distribution of this Official Statement for use in connection with the initial sale of the Bonds. As <br />of the date of the settlement of the Bonds, the Purchaser will be furnished with a certificate <br />signed by the appropriate officers of the Authority. The certificate will state that as of the date <br />of the Official Statement, it did not, and does not as of the date of the certificate contain any <br />untrue statement of material fact or omit to state a material fact necessary in order to make the <br />statements made therein, in light of the circumstances under which they were made, not <br />misleading. <br />• <br />-12- <br />
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