Guam Power Authority Revenue Refunding Bonds 2017 Series A
PRELIMINARY OFFICIAL STATEMENT DATED DECEMBER 7, 2017 NEW ISSUE – BOOK-ENTRY-ONLY RATINGS: (See “RATINGS” herein) In the opinion of Orrick, Herrington & Sutcliffe LLP, Bond Counsel to the Authority (“Bond Counsel”), based upon an analysis of existing laws, regulations, rulings and court decisions, and assuming, among other matters, the accuracy of certain representations and compliance with certain covenants, interest on the 2017A Senior Bonds is excluded from gross income for federal income tax purposes under Section 103 of the Internal Revenue Code of 1986 (the “Code”). In the further opinion of Bond Counsel, interest on the 2017A Senior Bonds is not a specific preference item for purposes of the federal individual or corporate alternative minimum taxes, nor is it included in adjusted current earnings when calculating corporate alternative minimum taxable income. Bond Counsel is also of the opinion that, under 48 U.S.C. Section 1423a, interest on the 2017A Senior Bonds is exempt from taxation by the government of Guam, or by any state or territory or any political subdivision thereof, or by the District of Columbia. Bond Counsel expresses no opinion regarding any other tax consequences related to the ownership or disposition of, or the amount, accrual or receipt of interest on, the 2017A Senior Bonds. See “TAX MATTERS” herein. $146,450,000* GUAM POWER AUTHORITY Revenue Refunding Bonds, 2017 Series A Dated: Date of Delivery Due: October 1, as shown on the inside front cover This cover page contains certain information for general reference only. It is not a summary of the security for or terms of the 2017A Senior Bonds.
[Show full text]