4-6-11 Sj Ccfd
NEW ISSUE – BOOK ENTRY ONLY RATINGS: Moody’s: “A2” S&P: “A-” See “RATINGS.” In the opinion of Orrick, Herrington & Sutcliffe LLP, 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 2011 Bonds is excluded from gross income for federal income tax purposes under Section 103 of the Internal Revenue Code of 1986 and is exempt from State of California personal income taxes. In the further opinion of Bond Counsel, interest on the 2011 Bonds is not a specific preference item for purposes of the federal individual and corporate alternative minimum taxes, although Bond Counsel observes that such interest is included in adjusted current earnings when calculating corporate alternative minimum taxable income. Bond Counsel expresses no opinion regarding any other tax consequences related to the ownership or disposition of, or the accrual or receipt of interest on, the 2011 Bonds. See “LEGAL MATTERS - Tax Matters.” $107,425,000 CITY OF SAN JOSE SPECIAL HOTEL TAX REVENUE BONDS, SERIES 2011 (CONVENTION CENTER Expansion AND Renovation PROJECT) Dated: Date of Delivery Due: May 1, as shown on inside cover Authority for Issuance. The bonds captioned above (the “2011 Bonds”) are being issued by the City of San José (the “City”) under Chapter 14.32 of the Municipal Code of the City of San José (the “Chapter”) and an Indenture, dated as of April 1, 2011 (the “Indenture”), by and between the City and U.S. Bank National Association, as trustee (the “Trustee”).
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