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RES 2024025
City of Pleasanton
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CITY CLERK
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2020-present
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2024
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RES 2024025
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5/10/2024 4:29:09 PM
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5/10/2024 4:27:36 PM
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CITY CLERK
CITY CLERK - TYPE
RESOLUTIONS
DOCUMENT DATE
5/7/2024
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<br /> <br /> <br />46 <br />original offering to the public at the first price at which a substantial amount of such 2024 Bonds <br />is sold to the public. <br /> <br />Under the Tax Code, original issue premium is amortized on an annual basis over the <br />term of the 2024 Bond (said term being the shorter of the 2024 Bond's maturity date or its call <br />date). The amount of original issue premium amortized each year reduces the adjusted basis of <br />the owner of the 2024 Bond for purposes of determining taxable gain or loss upon disposition. <br />The amount of original issue premium on a 2024 Bond is amortized each year over the term to <br />maturity of the 2024 Bond on the basis of a constant interest rate compounded on each interest <br />or principal payment date (with straight-line interpolations between compounding dates). <br />Amortized bond premium is not deductible for federal income tax purposes. Owners of premium <br />2024 Bonds, including purchasers who do not purchase in the original offering, should consult <br />their own tax advisors with respect to State of California personal income tax and federal <br />income tax consequences of owning such 2024 Bonds. <br /> <br />California Tax Status. In the further opinion of Bond Counsel, interest on the 2024 <br />Bonds is exempt from California personal income taxes. <br /> <br />Other Tax Considerations. Current and future legislative proposals, if enacted into <br />law, clarification of the Tax Code or court decisions may cause interest on the 2024 Bonds to be <br />subject, directly or indirectly, to federal income taxation or to be subject to or exempted from <br />state income taxation, or otherwise prevent beneficial owners from realizing the full current <br />benefit of the tax status of such interest. The introduction or enactment of any such legislative <br />proposals, clarification of the Tax Code or court decisions may also affect the market price for, <br />or marketability of, the 2024 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 <br />or as to the tax treatment of interest on the 2024 Bonds, or as to the consequences of owning or <br />receiving interest on the 2024 Bonds, as of any future date. Prospective purchasers of the 2024 <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 2024 Bonds should also be aware that the ownership or disposition of, or <br />the accrual or receipt of interest on, the 2024 Bonds may have federal or state tax <br />consequences other than as described above. Other than as expressly described above, Bond <br />Counsel expresses no opinion regarding other federal or state tax consequences arising with <br />respect to the 2024 Bonds, the ownership, sale or disposition of the 2024 Bonds, or the amount, <br />accrual or receipt of interest on the 2024 Bonds. <br /> <br /> <br />CERTAIN LEGAL MATTERS <br /> <br />Jones Hall, A Professional Law Corporation, Bond Counsel, will render an opinion with <br />respect to the validity of the 2024 Bonds, the form of which opinion is set forth in APPENDIX E. <br />Certain legal matters will also be passed upon for the City by Jones Hall, as Disclosure Counsel <br />and by the City Attorney. Certain legal matters will be passed upon for the Underwriter by its
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