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21 ATTACHMENT 3
City of Pleasanton
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CITY CLERK
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AGENDA PACKETS
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2021
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072021
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21 ATTACHMENT 3
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7/15/2021 2:13:11 PM
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7/15/2021 1:02:08 PM
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CITY CLERK
CITY CLERK - TYPE
AGENDA REPORT
DOCUMENT DATE
7/20/2021
DESTRUCT DATE
15Y
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21
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\CITY CLERK\AGENDA PACKETS\2021\072021
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<br />88 <br />discount, including the treatment of purchasers who do not purchase in the original offering to the <br />public at the first price at which a substantial amount of such 2021 Bonds is sold to the public. <br /> <br />Under the Tax Code, bond premium is amortized on an annual basis over the term of the <br />2021 Bond (said term being the shorter of the 2021 Bond's maturity date or its call date). The <br />amount of bond premium amortized each year reduces the adjusted basis of the owner of the <br />2021 Bond for purposes of determining taxable gain or loss upon disposition. The amount of <br />bond premium on a 2021 Bond is amortized each year over the term to maturity of the 2021 Bond <br />on the basis of a constant interest rate compounded on each interest or principal payment date <br />(with straight-line interpolations between compounding dates). Amortized 2021 Bond premium is <br />not deductible for federal income tax purposes. Owners of premium 2021 Bonds, including <br />purchasers who do not purchase in the original offering, should consult their own tax advisors <br />with respect to State of California personal income tax and federal income tax consequences of <br />owning such 2021 Bonds. <br /> <br />California Tax Status. In the further opinion of Bond Counsel, interest on the 2021 Bonds <br />is exempt from California personal income taxes. <br /> <br />Other Tax Considerations. Current and future legislative proposals, if enacted into law, <br />clarification of the Tax Code or court decisions may cause interest on the 2021 Bonds to be <br />subject, directly or indirectly, to federal income taxation or to be subject to or exempted from state <br />income taxation, or otherwise prevent beneficial owners from realizing the full current benefit of <br />the tax status of such interest. The introduction or enactment of any such legislative proposals, <br />clarification of the Tax Code or court decisions may also affect the market price for, or <br />marketability of, the 2021 Bonds. It cannot be predicted whether or in what form any such <br />proposal might be enacted or whether, if enacted, such legislation would apply to bonds issued <br />prior to enactment. <br /> <br />The opinions expressed by Bond Counsel are based upon existing legislation and <br />regulations as interpreted by relevant judicial and regulatory authorities as of the date of such <br />opinion, and Bond Counsel has expressed no opinion with respect to any proposed legislation or <br />as to the tax treatment of interest on the 2021 Bonds, or as to the consequences of owning or <br />receiving interest on the 2021 Bonds, as of any future date. Prospective purchasers of the 2021 <br />Bonds should consult their own tax advisors regarding any pending or proposed federal or state <br />tax legislation, regulations or litigation, as to which Bond Counsel expresses no opinion. <br /> <br />Owners of the 2021 Bonds should also be aware that the ownership or disposition of, or <br />the accrual or receipt of interest on, the 2021 Bonds may have federal or state tax consequences <br />other than as described above. Other than as expressly described above, Bond Counsel <br />expresses no opinion regarding other federal or state tax consequences arising with respect to <br />the 2021 Bonds, the ownership, sale or disposition of the 2021 Bonds, or the amount, accrual or <br />receipt of interest on the 2021 Bonds. <br /> <br /> <br />APPROVAL OF LEGALITY <br /> <br />The issuance of the 2021 Bonds is subject to the approving opinion of Jones Hall, A <br />Professional Law Corporation, San Francisco, California, Bond Counsel, with respect to validity <br />and tax exemption. Jones Hall is also acting as Disclosure Counsel to LAVWMA. Certain legal <br />matters will be passed upon for LAVWMA by its General Counsel, Jarvis, Fay & Gibson, LLP, and <br />for the Members by their respective counsels. Certain legal matters will be passed on for the
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