EMMA Official Statement
NEW ISSUE – BOOK ENTRY ONLY RATINGS: Moody’s: Aaa Standard & Poor’s: AAA See “Ratings” herein. In the opinion of Orrick, Herrington & Sutcliffe LLP, Bond Counsel to the District, 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 Tax-Exempt Bonds is excluded from gross income for federal income tax purposes under Section 103 of the Internal Revenue Code of 1986. In the further opinion of Bond Counsel, interest on the Tax-Exempt Bonds is not a specific preference item for purposes of the federal alternative minimum tax. Bond Counsel is also of the opinion that interest on the 2019 Bonds is exempt from State of California personal income taxes. Bond Counsel further observes that interest on the Taxable Bonds is not excluded from gross income for federal income tax purposes under Section 103 of the Code. 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 2019 Bonds. See “TAX MATTERS” $643,500,000 SAN FRANCISCO BAY AREA RAPID TRANSIT DISTRICT GENERAL OBLIGATION BONDS $313,205,000 $205,100,000 (ELECTION OF 2016), (ELECTION OF 2004), 2019 SERIES B-1 2019 SERIES F-1 (GREEN BONDS) (GREEN BONDS) $46,795,000 $34,900,000 (ELECTION OF 2016), (ELECTION OF 2004), 2019 SERIES B-2 (FEDERALLY TAXABLE) 2019 SERIES F-2 (FEDERALLY TAXABLE) (GREEN BONDS) (GREEN BONDS) $43,500,000 (ELECTION
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