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Declaring the official intent of the City to reimburse certain original expenditures related to the capital projects from the proceeds of tax-exempt bonds to be issued by the City after the payment of such original expenditures.
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WHEREAS, U.S. Treasury Regulations, Section 1.150-2 (the “Reimbursement Regulations”), promulgated pursuant to Section 150 of the Internal Revenue Code of 1986, as amended (the “Code”), provides that the allocation of the proceeds of tax-exempt bonds to expenditures for governmental purposes originally paid from a source other than such tax-exempt bonds will be treated as expenditures of such tax-exempt bonds only if certain requirements of the Reimbursement Regulations are satisfied by the issuer of such tax-exempt bonds; and
WHEREAS, the City of Saint Paul (the “City”), expects to pay certain original capital expenditures for items such as, but not limited to, (i) the projects shown on Exhibit A hereto and identified in the City’s approved Capital Improvement Budget for the years 2025 through 2029 (the “Projects”), and (ii) costs of issuance; which original expenditures are expected to be financed from other temporary sources, and which original expenditures are expected to be reimbursed from the proceeds of one or more series of tax-exempt bonds.
NOW, THEREFORE, BE IT RESOLVED BY THE CITY COUNCIL OF THE CITY OF SAINT PAUL, MINNESOTA, AS FOLLOWS:
1. The City has a reasonable expectation (within the meaning of Treasury Regulations, Section 1.148-1(b)) that it will make expenditures for the Projects in 2025 and 2026. The City has a reasonable expectation that it will issue one or more series of tax-exempt bonds (the “Bonds”) in the estimated principal amount of $140,727,821 to finance the Projects and that the City will make reimbursement allocations with respect to such original expenditures for the Projects from the proceeds of such Bonds.
2. This Resolution shall be maintained as p...
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