$262,865,000 the City of Philadelphia, Pennsylvania General Obligation Refunding Bonds, Series 2017
NEW ISSUE—BOOK-ENTRY ONLY RATINGS: Fitch: “A-” Moody’s: “A2” / “A2” (Insured Bonds) S&P: “A+” / “AA” (Insured Bonds) See “RATINGS” herein. In the opinion of Co-Bond Counsel, interest on the 2017 Bonds will be excluded from gross income for federal income tax purposes under existing statutes, regulations, rulings and court decisions, subject to the conditions described in “TAX MATTERS” herein. In addition, interest on the 2017 Bonds will not be treated as an item of tax preference under Section 57 of the Internal Revenue Code of 1986, as amended (the “Code”), for purposes of the individual and corporate alternative minimum taxes; however, under the Code, such interest may be subject to certain other taxes affecting corporate holders of the 2017 Bonds. Under the existing laws of the Commonwealth of Pennsylvania, interest on the 2017 Bonds will be free from Pennsylvania personal income taxation and Pennsylvania corporate net income taxation but such exemption does not extend to gift, estate, succession or inheritance taxes or any other taxes not levied or assessed directly on the 2017 Bonds or the interest thereon. For a more complete discussion, see “TAX MATTERS” herein. $262,865,000 THE CITY OF PHILADELPHIA, PENNSYLVANIA GENERAL OBLIGATION REFUNDING BONDS, SERIES 2017 Dated: Date of Delivery Due: August 1, as shown on inside cover page Defined Terms. All capitalized terms that are not otherwise defined on this cover page have the meanings provided to such terms in this Official Statement. The 2017 Bonds. The City of Philadelphia, Pennsylvania (the “City”), a corporation, body politic and city of the first class existing under the laws of the Commonwealth of Pennsylvania, is issuing the above-referenced bonds (the “2017 Bonds”).
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