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disruptions worldwide. The negative effects of the COVID-19 pandemic and its aftermath on global, national, and <br />local economies may continue at least for some period of time. Future pandemics and other widespread public <br />health emergencies may arise from time -to -time and can impact broader economic conditions in the affected <br />region and potentially worldwide. <br />Reduced economic activity and its associated impacts, including as a result of the outbreak of infectious <br />disease, such as job losses, income losses, business closures and housing foreclosures or vacancies, and any <br />prolonged recession that may occur, could have a variety of adverse effects on the City, the Water System <br />operations, and the region. Non-payment of utility bills and generalized reduced water usage from customers <br />resulting from the economic disruption may negatively affect the City and the Water System operations. A <br />protracted disruption in the manufacturing and processing of supplies and equipment may affect supply chains or <br />delay construction schedules for, or the implementation of, Water System capital improvement programs and <br />projects, and may increase the costs of such projects or programs or the Water System's operations. <br />Future pandemic and other widespread public health emergencies may arise from time -to -time and can <br />impact broader economic conditions in the affected region. Reduced economic activity and its associated impacts, <br />including as a result of the outbreak of infectious disease, such as job losses, income losses, business closures and <br />housing foreclosures or vacancies, and any prolonged recession that may occur, could have a variety of adverse <br />affects on City and in the region. Declines in assessed valuations in City service area and/or increases in property <br />tax delinquencies or non-payment resulting from the economic disruption may negatively affect property tax <br />collections and reduce tax levy receipts. Economic conditions affect aggregate levels of retail water use and may <br />reduce demands in the region and City's water transactions and revenues. A protracted disruption in the <br />manufacturing or construction industry may affect supply chains or delay construction schedules for, or the <br />implementation of, City's capital improvement programs and projects, and may increase the costs of such projects <br />or program or City's operations. A sustained deterioration in global stock market values may impact the market <br />value of assets held in fund City's pension and other post -employment benefit plans, which could result in future <br />increases in required plan contributions. The City cannot predict whether another national or localized outbreak <br />of highly contagious or epidemic disease in the future could negatively impact the City's operations and finances <br />and/or the economy of the regions it serves. <br />TAX MATTERS <br />In the opinion of Bond Counsel, based upon an analysis of existing laws, regulations, rulings and court <br />decisions, and assuming, among other matters, compliance with certain covenants, interest on the Bonds is <br />excluded from gross income for federal income tax purposes under Section 103 of the Internal Revenue Code of <br />1986 (the "Code") and is exempt from State of California personal income taxes. Bond Counsel is of the further <br />opinion that interest on the Bonds is not a specific preference item for purposes of the federal individual or <br />corporate alternative minimum taxes, provided however, that for the purpose of calculating federal corporate <br />alternative minimum tax imposed on corporations (as defined for federal income tax purposes), such interest is <br />taken into account in determining certain income and earnings. <br />The Code imposes various restrictions, conditions and requirements relating to the exclusion from gross <br />income for federal income tax purposes of interest on obligations such as the Bonds. The Authority has <br />covenanted to comply with certain restrictions designed to insure that interest on the Bonds will not be included <br />in federal gross income. Failure to comply with these covenants may result in interest on the Bonds being included <br />in federal gross income, possibly from the date of original issuance of the Bonds. The opinion of Bond Counsel <br />assumes compliance with these covenants. Bond Counsel has not undertaken to determine (or to inform any <br />person) whether any actions taken (or not taken) or events occurring (or not occurring) after the date of issuance <br />of the Bonds may adversely affect the value of, or the tax status of interest on, the Bonds. <br />Current and future legislative proposals, if enacted into law, clarification of the Code or court decisions <br />may cause interest on the Bonds to be subject, directly or indirectly, to federal income taxation or to be subject to <br />or exempted from state income taxation, or otherwise prevent Bond Owners from realizing the full current benefit <br />of the tax status of such interest. For example, legislative proposals are announced from time to time which <br />generally would limit the exclusion from gross income of interest on obligations like the Bonds to some extent <br />37 <br />