New York Transportation Development Corporation Special Facility Revenue Refunding Bonds, Series 2015 (Terminal One Group Association, L.P
New Issue – Book-Entry Only Ratings: See “Ratings” herein. In the opinion of Winston & Strawn LLP and the Hardwick Law Firm, LLC, Co-Bond Counsel, based on existing statutes, regulations, rulings and court decisions, interest on the Series 2015 Bonds is not included in gross income for federal income tax purposes and is not includable in taxable income for purposes of personal income taxes imposed by the State of New York, The City of New York and the City of Yonkers, New York, assuming compliance with certain covenants and the accuracy of certain representations, except that no opinion is expressed by Co-Bond Counsel as to the exclusion from such gross income and such taxable income of interest on any Series 2015 Bond during the period that such Series 2015 Bond is held by a “substantial user” of the facilities refinanced by the Series 2015 Bonds or a “related person” within the meaning of Section 147(a) of the Internal Revenue Code, as amended. In the further opinion of Co-Bond Counsel, interest on the Series 2015 Bonds is treated as an item of tax preference to be included in calculating the alternative minimum taxable income for purposes of the alternative minimum tax imposed with respect to individuals and corporations. See “Tax Matters” in this Official Statement. $167,260,000 ® New York Transportation Development Corporation Special Facility Revenue Refunding Bonds, Series 2015 (Terminal One Group Association, L.P. Project) Dated: Date of Issuance Due: January 1, as shown on the inside front cover The Special Facility Revenue Refunding Bonds, Series 2015 (Terminal One Group Association, L.P.
[Show full text]