Not to Cause Interest to Become Taxable. The District covenants that it shall not use, and shall not permit the use of, and shall not omit to use Gross Proceeds or any other amounts (or any property the acquisition, construction or improvement of which is to be financed directly or indirectly with Gross Proceeds) in a manner that if made or omitted, respectively, could cause the interest on any Bond to fail to be excluded, pursuant to section 103(a) of the Code, from the gross income of the owner thereof for federal income tax purposes. Without limiting the generality of the foregoing, unless and until the Fiscal Agent receives a written opinion of Bond Counsel to the effect that failure to comply with such covenant will not adversely affect such exclusion of the interest on any Bond from the gross income of the owner thereof for federal income tax purposes, the District shall comply with each of the specific covenants in this Section.
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Samples: Fiscal Agent Agreement, Fiscal Agent Agreement
Not to Cause Interest to Become Taxable. The District Authority covenants that it shall not use, and shall not permit the use of, and shall not omit to use Gross Proceeds or any other amounts (or any property the acquisition, construction or improvement of which is to be financed directly or indirectly with Gross Proceeds) in a manner that if made or omitted, respectively, could cause the interest on any Bond or Prior PFA Bond to fail to be excluded, excluded pursuant to section Section 103(a) of the Code, Code from the gross income income, of the owner thereof for federal income tax purposes. Without limiting the generality of the foregoing, unless and until the Fiscal Agent Trustee receives a written opinion of Bond Counsel to the effect that failure to comply with such covenant will not adversely affect such exclusion of the interest on any Bond or Prior PFA Bond from the gross income of the owner thereof for federal income tax purposes, the District Authority shall comply with each of the specific covenants in this Section.
Appears in 1 contract
Samples: Escrow Deposit and Trust Agreement
Not to Cause Interest to Become Taxable. The District covenants that it Neither the Agency nor the Authority shall not use, and shall not permit the use of, and shall not or omit to use Gross Proceeds or any other amounts (or any property the acquisition, construction or improvement of which is to be financed directly or indirectly with Gross Proceeds) in a manner that if made or omitted, respectively, could cause the interest on any Bond to fail to be excluded, excluded pursuant to section Section 103(a) of the Code, Code from the gross income of the owner thereof for federal income tax purposes. Without limiting the generality of the foregoing, unless and until the Fiscal Agent Agency or the Authority receives a written opinion of Bond Counsel to the effect that failure to comply with such covenant will not adversely affect such exclusion of the interest on any Bond from the gross income of the owner thereof for federal income tax purposes, the District Agency and the Authority, respectively, shall comply with each of the specific covenants in this Section.
Appears in 1 contract
Samples: Loan Agreement
Not to Cause Interest to Become Taxable. The Neither the District covenants that it nor the Participant shall not use, and shall not permit the use of, and shall not or omit to use Gross Proceeds or any other amounts (or any property property, the acquisition, construction or improvement of which is to be financed directly or indirectly with Gross Proceeds) in a manner that if made or omitted, respectively, could would cause the interest on any Bond of the Tax-Exempt Obligations to fail to be excludedbecome includable in the gross income, pursuant to as defined in section 103(a) 61 of the Code, from the gross income of the owner thereof for federal income tax purposes. Without limiting the generality of the foregoing, unless and until the Fiscal Agent receives District and the Participant receive a written opinion of Bond Counsel to the effect that failure to comply with such covenant will not adversely affect such the exclusion from gross income for federal income tax purposes of the interest on any Bond from the gross income of the owner thereof for federal income tax purposesTax-Exempt Obligation, the District and the Participant shall comply with each of the specific covenants in this Section.
Appears in 1 contract
Samples: agenda.slocounty.ca.gov