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each year while any of the Bonds are outstanding, commencing with property tax year 2016 -17, in amounts <br />equal to the principal of and interest on the Bonds coining due in the succeeding calendar year. Although the <br />matter is not free from doubt, it is likely that a court would hold that Article XIIIC has not conferred on the <br />voters the power to reduce or repeal the unpaid assessments which are pledged as security for payment of the <br />Bonds or to otherwise interfere with performance of the mandatory, statutory duty of the City and the County <br />Auditor with respect to the unpaid assessments which are pledged as security for payment of the Bonds. <br />The interpretation and application of the Initiative will ultimately be determined by the courts with <br />respect to a number of the matters discussed above, and it is not possible at this time to predict with certainty the <br />outcome of such determination. <br />Ballot Initiatives and Legislative Measures <br />The Initiative was adopted pursuant to a measure qualified for the ballot pursuant to California's <br />constitutional initiative process; and the State Legislature has in the past enacted legislation which has altered <br />the spending limitations or established minimum funding provision for particular activities. From time to time, <br />other initiative measures could be adopted by California voters or legislation enacted by the Legislature. The <br />adoption of any such initiative or legislation might place limitations on the ability of the State, the City or local <br />districts to increase revenues or to increase appropriations. <br />Impact of Legislative Proposals, Clarifications of the Code and Court Decisions on Tax Exemption <br />Future legislative proposals, if enacted into law, clarification of the Code of court decisions may cause <br />interest on the Bonds to be subject, directly or indirectly, to federal income taxation or to be subject to or <br />exempted from state income taxation, or otherwise prevent Beneficial Owners of the Bonds from realizing the <br />full current benefit of the tax status of such interest. <br />For example, Congress has considered in the past, is currently considering and may consider in the <br />future, legislative proposals, including some that carry retroactive effective dates, that, if enacted, would alter or <br />eliminate the exclusion from gross income for federal income tax purposes of interest on municipal bonds, such <br />as the Bonds. Prospective purchasers of the Bonds should consult their own tax advisors regarding any pending <br />or proposed federal tax legislation. <br />The introduction or enactment of any such future legislative proposals, clarification of the Code or court <br />decisions may also affect the market price for, or marketability of, the Bonds. Prospective purchasers of the <br />Bonds should consult their own tax advisors regarding any pending or proposed federal or state tax legislation, <br />regulations or litigation as to which Bond Counsel expresses no opinion. <br />No Acceleration <br />The Bonds do not contain a provision allowing for the acceleration of the Bonds in the event of a <br />payment default or other default under the terns of the Bonds or the Bond Resolution. There is no provision in <br />the Act or the Bond Resolution for acceleration of the Assessment Installments in the event of a payment default <br />by an owner of a parcel within the Assessment District or otherwise, or upon any adverse change in the tax <br />status of interest on the Bonds. Pursuant to the Bond Resolution, a Bondowner is given the right for the equal <br />benefit and protection of all Bondowners to pursue certain remedies described in the Fiscal Agent Agreement. <br />Loss of Tax Exemption <br />As discussed under the caption "TAX EXEMPTION" herein, interest on the Bonds could become <br />includable in gross income for purposes of federal income taxation retroactive to the date the Bonds were issued <br />as a result of future acts or omissions of the City in violation of its covenants in the Bond Resolution. Should <br />such an event of taxability occur, the Bonds are not subject to a special redemption and will remain outstanding <br />until maturity or until redeemed under one of the other redemption provisions contained in the Bond Resolution. <br />32 <br />55B -102 <br />