City and County of Honolulu, Hawaii General Obligation Bonds, Series 2011A and 2011B (Final Opinion)
NEW ISSUE RATINGS: FULL BOOK-ENTRY Fitch: AA+ Moody’s: Aa1 (See “Bond Ratings” herein) In the opinion of Orrick, Herrington & Sutcliffe LLP, Bond Counsel to the City and County, 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 Bonds is excluded from gross income for federal income tax purposes under Section 103 of the Internal Revenue Code of 1986, and the Bonds and the income therefrom are exempt from all taxation by the State of Hawaii or any county or other political subdivision thereof, except inheritance, transfer, estate and certain franchise taxes. In the further opinion of Bond Counsel, interest on the 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 federal 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 Bonds. See “TAX MATTERS” in this Official Statement. $304,345,000 CITY AND COUNTY OF HONOLULU General Obligation Bonds Series 2011A and 2011B Dated: Date of Delivery Due: August 1, as shown on inside cover The City and County of Honolulu General Obligation Bonds, Series 2011A and Series 2011B (the “Series 2011A Bonds” and “Series 2011B Bonds,” respectively, and together, the “Bonds”), are being issued by the City and County of Honolulu (the “City and County”) in fully registered form and when issued will be registered initially in the name of Cede & Co., as nominee of The Depository Trust Company (“DTC”), New York, New York.
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