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2jSours South Miami F< 3 ,'Illi INCO A2,AiED O Rtp P 2001 CITY OF SOUTH MIAMI OFFICE OF THE CITY MANAGER INTER - OFFICE MEMORANDUM To: The Honorable Mayor Stoddard and Memb of t ity Commission From: Roger M Carlton, Acting City Manager Date: May 3, 2010 61 6 Subject: IRS Tax Exempt Status for Municipal Garage Bonds and Ad Valorem Property Tax Status Included in the Manager's Report for the March 16, 2010 City Commission Meeting was an item related to the potential for the Municipal Parking Garage to lose its Ad Valorem Tax exemption for the portion of the garage that is used for public parking. The recommendation of the City Manager and the City Attorney was to retain expert legal counsel to assist us in completing a condominium regime that would ensure that the public parking portion would not be declared subject to Ad Valorem taxation. The discussion was truncated before the need could be explained and became the subject of a Committee of the Whole meeting on March 23, 2010. The outcome of that meeting is Resolution No. 69 -10- 131032 which provided specific direction to the Acting City Manager and the City Attorney. A key element of the direction was to keep lines of communication open with the County Attorney and Property Appraisers. That direction has been implemented. It should be clear to the City Commission that the lack of "splitting" the retail and parking portions of the garage as discussed during the COW meeting has a high probability of a determination that the entire garage will be subject to property taxes. Further, the structure of this agreement with Mr. Richman wherein be keeps the profit for the parking and pays the City a base rent plus a percentage over a certain revenue level further exacerbates this problem and enhance the risk of taxability. This is not the only problem. That same payment structure puts the tax exempt bonds which were used to finance the project at risk of losing that status from the IRS. See Attachment 2 and 3 which explain a similar situation for the bonds which were issued to finance the Kravis Center in Palm beach County. A portion of those bonds used to build the ballroom and kitchen which was operated by a for - profit entity were declare taxable as the result of an IRS random audit. The outcome was that Palm Beach County had to call a portion of the bonds ($2.88 Million) that related to the ballroom and kitchen and a settlement in the amount of $320,000 was required. Attachment 4 is a series of e -mails between the League of Cities, the bond issuer, the former South Miami City Attorney, City staff and the Bond Counsel Bryant Miller Olive reflecting an understanding that the Municipal Garage documents would be revised to clarify ambiguities and ensure that the bonds did not became taxable. This did not happen. Members of the City Commission, it is critical that you authorize the City Attorney and Acting City Manager to retain appropriate counsel to resolve this matter before this financial risk becomes reality. I have placed this matter before you, because it is my responsibility in conjunction with the City Attorney to protect this Commission and the community from the risks resulting from inaction on amending the documents. Attachments: 68 -10 -13102 10. A resolution of the Mayor and City Commission of the City of South Miami, Florida directing the Planning and Zoning Department and the Planning Board to consider an ordinance revising Land Development Code Section 20 -8.9 entitled "Special exceptions" in order to set a time limit for commencing a development project which has been granted a special exception in a Transit Oriented Development District (TODD); and providing for an effective date. (Deferred 3115110) 3/5 (Acting City Manager) Moved by Commissioner Beasley, seconded by Mayor Stoddard, the motion to approve this item passed by a 5 -0 vote. Commissioner Beasley: Yea; Vice Mayor Newman: Yea; Commissioner Harris: Yea; Commissioner Palmer: Yea; Mayor Stoddard: Yea. 69 -10 -13103 11. A resolution of the Mayor and City Commission of the City of South Miami, Florida instructing the City Manager and the City Attorney on proceeding with the outstanding issues concerning the Municipal Garage and the Lease Agreement with Mark Richman Properties; and providing an effective date. 3/5 (vice Mayor Newman) Moved by Commissioner Beasley, seconded by Vice Mayor Newman, the motion to approve this item as amended passed by a 5- 0 vote. Commissioner Beasley: Yea; Vice Mayor Newman: Yea; Commissioner Harris: Yea; Commissioner Palmer: Yea; Mayor Stoddard: Yea. (Alternate) This item was withdrawn 11. A resolution of the Mayor and City Commission of the City of South Miami, Florida instructing the City Manager and the City Attorney on proceeding with the outstanding issues concerning the Municipal Garage and the Lease Agreement with Mark Richman Properties; and providing an effective date. 3/5 (Mayor Stoddard) 70 -10 -13104 12. A resolution of the Mayor and City Commission of the City of South Miami, Florida instructing the City Manager to proceed with certain limited phases of the Murray Park pool project; and providing an effective date. 3/5 (Mayor Stoddard) Moved by Commissioner Beasley, seconded by Commissioner Palmer, the motion to approve this item passed by a 5 -0 vote. REGULAR CITY COMMISSION 3 AFTER ACTION SUMMARY - April 6, 2010 Performing Arts Center Pays IRS - Bond Buyer Article ins THE DAILY NEWSPAPER OF PUBLIC FINANCE Performing Arts Center Pays IRS Fla, Nonprofit Settles Over Bond- Backed Ballroom's Use Monday, April 26, 2010 By Shelly Sigo Page 1 of 2 BRADENTON, Fla. — The nonprofit Raymond F. Kravis Center for the Performing Arts Inc. in Palm Beach County, Fla., has paid $320,000 to the Internal Revenue Service to settle a violation of the Internal Revenue Code's 5% limit on private use in a bond - financed facility. The violation concerned a private vendor's use of a ballroom built with a portion of the proceeds of $41.5 million of tax - exempt variable -rate demand revenue bonds that were sold on behalf of Kravis in 2002, Palm Beach County was the conduit issuer. Palm Beach County commissioners last week approved a resolution accepting receipt of settlement closing documents between the Kravis Center and the IRS, county records show. As part of the settlement, the Kravis Center has already called $2.8B million of the outstanding variable -rate bonds, which will be redeemed by May 3, according to a redemption notice published on the Municipal Securities Rulemaking Board's Electronic Municipal Market Access system. In a random audit, the IRS examined a contract between Kravis and a for - profit company operating in a food service area of a facility financed with tax - exempt bonds and determined that non - qualifying use had occurred, said John Theberge, a partner and public finance tax expert at Holland It Knight hired to represent Kravis in the matter. "We didn't necessarily agree with the IRS," Theberge said, adding that negotiations were unsuccessful in convincing the IRS that the contract did not violate safe harbor provisions. "They were pretty adamant so we just decided to compromise." Theberge said that there was no deliberate intent on the part of the Kravis Center to violate bond regulations and that performing arts center officials believed the contract they entered was proper. "We didn't think it was a violation but we wanted to just resolve the issue and protect the bondholders," Theberge said. "Kravis tried to do the right thing. It's a done deal." Robert Henn, manager of tax - exempt bond field operations for the IRS, said the agency had no comment on the settlement with Kravis. Generally, however, Henn said all private nonprofit organizations that benefit from the use of tax - exempt financing need to be careful with the contracts they enter to ensure they don't violate the IRS code. "The rules are pretty clear and many people follow them well," Henn said. Travis Gibbs, a partner at Nixon Peabody who is a bond and tax attorney familiar with nonprofit issues, said service contracts such as this one represent an area where there are helpful and definitive guidelines on arranging the contracts to avoid problems with the 5% rule. The IRS has recently required nonprofits to file an additional form annually regarding each tax- exempt bond issue with an outstanding principal balance of more than $100,000 where the tax - exempt organization is the http: / /www.bondbuyer.com/ issues / 119_ 327 /raymond_kravispalm— beach - 101127$- l.html... 4/27/2010 Performing Arts Center Pays IRS - Bond Buyer Article Page 2 of 2 beneficiary. The form requires substantial information about bonds issued since 2003, including non - quatified use of the bond - financed assets, Gibbs said. Theberge said the settlement protects the tax- exempt status of the remaining outstanding variable -rate bonds. The tong -term rating on the bonds is Aa3 from Moody's Investors Service, the only agency that rates them. The Kravis Center operates three venues — a 2,193 -seat concert hall, a 300 -seat playhouse, and an outdoor amphitheater with a capacity for 1,400. In addition to purchasing a parking garage and doing renovations, the bonds issued in 2002 were used to replace an existing catering and meeting facility with a Larger building that also contained a rehearsal hall, education center, recording studio, offices, and a board room. Copy of Brief m 2010 The Bond Buyer and SourceMedia Inc., All rights reserved. Use, duplication, or sale of this service, or data contained herein, except as described in the subscription agreement, is strictly prohibited. Trademarks page. Client Services 1- 800 - 221 -1809, 8:30am - 5:30pm, ET For information regarding Reprint Services please visit: http: / /ticense.icopyright. net /3.7745 ?icx_id- 20090817FNNRUTWS http: / /www.bondbtiyer.com/issues /119 - 327 /raymond_kravis palm— beach - 1011278- 11tml... 4/27/2010 Agenda Item OP. b i PALM BEACH COUNTY BOARD OF COUNTY COMMISSIONERS AGENDA ITEM SUMMARY Meeting Date: 4/2012010 Department Submitted By: COUNTY ATTORNEY Submitted For: [X] Consent [] Regular [ ] Public Hearing 1. EXECUTIVE BRIEF Motion and Title: Staff recommends motion to receive and file the executed Closing Agreement on Final Determination Covering Specific Matters dated Mareh.11, 2010 (the "Closing Agreement "), by and among The Raymond F. Kravis Center for the Performing Arts (the "Borrower"), Palm Beach County, Florida (the "Issuer") and the Internal Revenue Service (the "Service"). Summary: Resolution No. 2002 -0681 authorized issuance of industrial development bonds for The Raymond F. Kravis Center for the Performing Arta Project, Series 2002 (the "Bonds "). A review of the Bonds by the Service concluded that the Borrower failed to meet certain requirements of Section 103 of the Internal Revenue Code, The Closing Agreement settled certain matters covered under the Service's examination, resulting in the Borrower paying $320,000 and redeeming a portion of the outstanding Bonds. The parties have executed the Closing Agreement and it should now be received and filed in the Minutes Department. Countywide (PFK) Background and Justification: Section 13 of Resolution No. 2002 -0681 authorized the Chair's execution of the Closing Agreement on behalf of the Issuer. The Minutes Department has requested that the Closing Agreement be presented as "receive and file" for acceptance Into the official records of the Board of County Commissioners of Palm Beach County. Attachments: 1. Closing Agreement on Final March 11, 2010 Recommended by: Approved by: Covering Specific Matters dated Date 10 CLOSING AGREEMENT ON FINAL DETERMINATION COVERING SPECIFIC MATTERS Under section 7121 of the internal Revenue Code of 1986, as amended (the "Code'), Palm Beach County, EIN 69. 6000785, (the "Issuer"), The Raymond F. Kravis Center for the Performing Arts, EIN 59- 2245054, (the "Borrower7, and the Commissioner.0f Internal Revenue (the "Service "), make this closing agreement (the "Agreement"). WHEREAS, the parties have determined the following facts and made the following legal conclusions and representations: A. This Agreement la in settlement of Issues raised In an examination of the $41,500,000 Variable Rate Demand Revenue Bonds (The Raymond R Kravis Center for the Performing Arta Project) Series 2002, dated June 3, 2002, and Issued June 4, 2002 (the °Bondsj, B. The Service has conducted an examination of the Bonds and concluded that the Bonds fail to meet the requirements of section 103 of the Code as a result of private business use of Ballroom Level 1 of the Cohen Pavillon. Consequently, 95% of net proceeds were not used for the qualified purpose as required under Section 145(a) (2) (B) of the Code. C. The Service has not formally asserted any claims against the Issuer, or the Borrower, or sought to tax any holders of the Bonds on Interest Income on the Bonds. D. The Issuer, the Borrower, and the Service desire to settle the issues raised during the examination of the Bonds. E. The terms of this Agreement were arrived at by negotiation between the Issuer, the Borrower, and the Service, and may differ from the terms of settlement of other bond issues examined or to be examined by the Service. F. This Agreement Is for the benefit of the past, present and future registered and beneficial owners of the Bonds (collectively, "the Bondholders ").' NOW, IT IS HEREBY DETERMINED AND AGREED PURSUANT TO THIS CLOSING AGREEMENT EXECUTED BY THE PARTIES HERETO UNDER CODE SECTION 7121 THAT FOR FEDERAL INCOME TAX PURPOSES: I. Prior to the execution and delivery of this Agreement, sum of $320,000 (Three Hundred Twenty Thousand Dollars) (the `Settlement Amount") will be paid to the Service As the Electronic Federal Tax Payment System and In accordance with the directions contained in Exhibit of this Agreement. Payment of the Settlement Amount shall not be made from proceeds of bonds described In section 103(a) of the Code. Page I of CLOSING AGREBMBNT between Palm Beach County, Florida (BIN 596000785), Pot Issuer; The Raymond F. Kravis Center for the Performing Arta (BIN 59- 2245054), the Borrower, and thu ittarnat Revenue service b) it is subject to sections of the Code that expres* provide that effect be given to theft provisions (including any stated exceptions for section 7122) notwithstanding any other law or rule of law; and c) if it relates to a tax period ending after the effective date of this agreement, It is subject to any law enacted after the Agreement date that applies to that tax period. By signing, the above parties certify that they have read and agreed to the terms of this Agreement. Palm Beach County, Florida 59.6080786 SIGNATURe' i?,,tr" AAA -4-9 OrJ NAME (PLEASE PRINT) C1lAtPA j ACC. APPROVED AS TO FORM TITLE l AN LEQAL S FFICIENCY 3 + ti / 1 o o,,^ 1�} DATE COUNTY~ RNEV- CONDUIT BORROWER: The Raymond F v7 "enta for the Performing Arts MN: 59- 2245054 BY: SIGNATURE NAME (PLEASE PRINT) C i1a'i,c.N r1'ni TITLE DATE Pago 3 of5 CLOSING AGREEMENT between Palm Beach County, Florida (BIN 59- 6000785), the Issuer; The Raymood F. Kravis Centet for the Performing Arft (RIN 59. 2245054), the Borrower, and the internal Revenue Sorvice Exhibit A Taxpayer Information Worksheet for Electronic Federal Tax Payment System Deposit This Agreement requires the electronic deposit of an amount to the U.S. Treasury through the Electronic Federal Tax Payment System (EFTPS) as a term for resolution of certain identified matters related to the tax - exempt treatment of Interest Income paid on a municipal obligation. This payment must be deposited in accordance with the directions contained in this Exhibit. Please carefully review the taxpayer information listed below and immediately report any errors to the IRS Tax Exempt Bonds employee assigned to your case. If, to the best of your knowledge, the information is correct, then please deposit all required payments through the EFTPS (either EFTPS — Direct or EFTPS — through a Financial Institution) accurately and in accordance with this information and the terms of this Agreement 1. Total Amount of Tax Deposit $320,00 2. Taxpayer's Employee Identification Number (EIN): 68.8000788 3. Taxpayer Name Control (4 characters): PALM 4. Taxpayer Name (up to 36 characters): PAf.M 13EACH COUNTY, FLORIDA 5. Tax Type (5 characters): 80384 6. Tax Year (2 digits): 02 7. Tax Month (2 digits): 106 Your financial Institution may cast the EFTPS Financial Institution Welpline for questions or assistance at 1- 800.605.9876 (Monday— Friday, 8:00 a.m. — 8:00 p.m., Easterh Standard Time), NOTE: If you are lint enrolled in EFTPS — Direct or EFTPS — through a Fine noial Institution, or otherwise wish to use the Same Day Payment option, then please provide your financial Institution with the information listed above and direct them to accurately deposit your payments utilizing the following routing and account numbers; Routing Number (RTN): 061030164 FRB MPLS ETA Account Number: 20092900 It the financial institution has difficulty transmitting the EFTPS same -day payment, Please Cali i- 800- 382 -0046 (Monday — Friday, 7:45 a.m. —4:30 p.m. Central Standard Time) to receive assistance from a Customer Service Representative at the Minneapolis Federal Reserve Bank. Page 5 of 5 Page 1 of 1 Carlton, Roger From: Zamira Ramirez [zramirez @bmolaw.com] on behalf of Jolinda Herring gherring @bmolaw.com] Sent: Wednesday, April 21, 2010 9:07 AM To: Carlton, Roger Subject: City of South Miami Hi Roger: Thank you for meeting with me and Dick Montalbano on yesterday. As promised, attached is the communication related to the issue on the parking garage. Please feel free to call me if you have questions. JoLinda Herring Bryant Miller Olive One Biscayne Tower 2 South Biscayne Boulevard, Suite 1480 Miami, Florida 33131 Telephone: (305) 374 -7349 Fax: (305) 374 -0895 iolinda @bmolaw.com TAX ADVICE DISCLOSURE: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein. NOTICE TO RECIPIENT: This e -mail message is intended only for the individual or entity to which it is addressed and may contain confidential information and /or attachments that are legally privileged. If you are not the intended recipient, any review, use, dissemination, distribution or copying of this e -mail is strictly prohibited. If you have received this e -mail in error, please notify us immediately by return e -mail or by telephone and delete this message. Please note that if this e -mail contains a forwarded message, an attachment, or is in reply to a prior message, some or all of the contents of this message may not have been produced by Bryant Miller Olive P.A. 4/22/2010 South Miami and interiocal question Page I of I Jolinda Herring From: Melanie Gillespie [MGillespie @flcities.com] Sent: Wednesday, July 16, 2008 3:27 PM To: Jolinda Herring Subject: South Miami and interiocal question I spoke with the new FD at South Miami and they are working on a new management contract that they will send to us. After today, I am out until next Tuesday and will check in with her again until we get something. Also, the other borrower who has the library does have an interlocal with the county. When I receive it, I will forward to you. Thanks. Melanie ,jillespie Loan `5clviccs Manager L[orida League of Cities, kc.. 850.'01.364 1 direct 850.3L0.Oi84 mo[�i�e. 850.222. 806 fax iq. -digit code:.5 '+ 4/20/2010 Message Jolinda Herring From: Jolinda Herring Sent: Tuesday, June 03, 2008 11:04 AM To: 'Luis Figueredo' Subject: FW: City of South Miami Fli Luis: Just checking to see if the Management Contract has been approved yet? - - - -- Original Message---- - From: Jolinda Herring Sent: Tuesday, April 29, 2008 3:28 PM To. 'Luis Figueredo' Subject: City of South Miami Hi Luis: Page 1 of I Just checking to see how the Management Contract was progressing for the City of South Miami. Please let me know if there is anything I can do. JoLinda Herring Bryant Miller Olive One Biscayne Tower 2 South Biscayne Boulevard, Suite 1480 Miami, Florida 33131 Telephone: (305) 374 -7349 Fax: (305) 374 -0895 jolinda@bmolaw.com TAX ADVICE DISCLOSURE: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein. NOTICE TO RECIPIENT: This e -mail message is intended only for the individual or entity to which it is addressed and may contain confidential information and /or attachments that are legally privileged. If you are not the. intended recipient, any review, use, dissemination, distribution or copying of this e-mail is strictly prohibited. If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone and delete this message. Please note that if this e-mail contains a forwarded message, an attachment, or is in reply to a prior message, some or all of the contents of this message may not have been produced by Bryant Miller Olive P.A. 4/20/2010 Message Jolinda Herring From: Jolinda Herring Sent: Tuesday, March 25, 2008 9:53 AM To: Len Marcinko Subject: FW: FMLC conf. call with the City of South Miami Attachments: FMLC conf. call with the City of South Miami Tracking: Recipient Delivery Len Marcinko Delivered: 3/25/2008 9:53 AM Len, Page I of 2 Can you participate on this call? Bob Reid has been helping, but will be out after today. JoLinda Herring Bryant Miller Olive 'One Biscayne Tower 2 South Biscayne Boulevard, Suite 1480 Miami, Florida 33131 Telephone: (305) 374 -7349 Fax: (305) 374-0895 johnda@bmolaw.com TAX ADVICE DISCLOSURE: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein. NOTICE TO RECIPIENT: This e -mail message is intended only for the individual or entity to which it is addressed and may contain confidential information and/or attachments that are legally privileged. If you are not the intended recipient, any review, use, dissemination, distribution or copying of this e-mail is strictly prohibited. If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone and delete this message. Please note that if this e-mail contains a forwarded message, an attachment, or is in reply to a prior message, some or all of the contents of this message may not have been produced by Bryant Miller Olive P.A. - - -- ;.Original Message---- - From: Hudgins, Debra [ mailto: debra .hudgins @bankofamerica.com] Sent: Tuesday, March 25, 2008 9:48 AM To: Mason, Linda A; Garrett, Patricia A; Gough, Glenn P; mgmenendez @cityofsouthmiami.net; Mark Raymond; Jeannie Garner; mglllespie @ficities.com; Jolinda Herring Subject: FMLC conf. call with the City of South Miami 4/20/2010 Message When: Thursday, March 27, 2008 11:00 AM -11:30 AM (GMT- 05:00) Eastern Time (US & Canada). Where: Bridgeline: (866) 285 -7712 Passcode: 4625817 4/20/2010 Page 2 of 2 Jolinda Herrin From: Bob Reid Sent: Monday, March 24, 2008 10:10 AM To: Jolinda Herring Subject: Re: Sunshine State - City of South Miami Anything related to this project. C1118 ' ,I Bryant Miller Olive 101 North Monroe Street, Suite 900 Tallahassee, Florida 32301 (850) 222 -8611 (850) 222 -8969 (fax) TAX ADVICE DISCLOSURE: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein. NOTICE TO RECIPIENT: This e -mail message is intended only for the individual or entity to which it is addressed and may contain confidential information and /or attachments that are legally privileged. If you are not the intended recipient, any review, use, dissemination, distribution or copying of this e- mail is strictly prohibited. If. you have received this e -mail in error, please notify us immediately by return e -mail or by telephone and delete this message. Please note that if this e -mail contains a forwarded message, an attachment, or is in reply to a prior message, some or all of the contents of this message may not have been produced by Bryant Miller Olive P.A. - - -- Original Message - - - -- From: Jolinda Herring To: Bob Reid Sent: Mon Mar 24 09:49:012008 Subject: RE: Sunshine State - City of South Miami Would that make the whole transaction taxable? Even the outstanding loan? JoLinda Herring Bryant Miller Olive One Biscayne Tower 2 South Biscayne Boulevard, Suite 1480 Miami, Florida 33131 Telephone: (305) 374 -7349 Fax: (305) 374 -0895 jolinda@bmolaw.com <mailto:jolinda@bmolaw.com> TAX ADVICE DISCLOSURE: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein. NOTICE TO RECIPIENT: This e -mail message is intended only for the individual or entity to which it is addressed and may contain confidential information and /or attachments that are legally privileged. If you are not the intended recipient, any review, use, dissemination, distribution or copying of this e- mail is strictly prohibited. If you have received this e -mail in error, please notify us immediately by return e -mail or by telephone and delete this message. Please note that if this e -mail contains a forwarded message, an attachment, or is in reply to a prior message, some or all of the contents of this message may not have been produced by Bryant Miller Olive P.A. - - - -- Original Message---- - From: Bob Reid Sent: Sunday, March 23, 200811:45 AM To: Jolinda Herring Subject: Sunshine State - City of South Miami JoLinda, I am troubled by the City lease with MRP. The lease results from a Settlement agreement between the City and MRP which requires the city to go forward with the development, and the developer /lessee (MRP) to pay rent plus all bond debt service. The Leae is for a 50 year term (does not fit any exception for management contracts). The rent is set forth in section 5 (and includes a cross reference to 9.1.2(c) that does not make sense). This agreement appears to require a lot of reworking to make it work and keep the Sunshine State loan tax exempt. We can try and chat Monday, but Tuesday would be better. I will be out of the Country from Wednesday until April 8. Bob Reid Bryant Miller Olive 101 North Monroe Street, Suite 900 Tallahassee, Florida 32301 (850) 222 -8611 (850) 222 -8969 (fax) TAX ADVICE DISCLOSURE: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein. NOTICE TO RECIPIENT: This e -mail message is intended only for the individual or entity to which it is addressed and may contain confidential information and /or attachments that are legally privileged. If you are not the intended recipient, any review, use, dissemination, distribution or copying of this e -mail is strictly prohibited. If you have received this e -mail in error, please notify us immediately by return e -mail or by telephone and delete this message. Please note that if this e -mail contains a forwarded message, an attachment, or is in reply to a prior message, some or all of the contents of this message may not have been produced by Bryant Miller Olive P.A. Message Jolinda Herring From: Jolinda Herring Sent: Monday, March 03, 2008 2:05 PM To: 'Luis Figueredo' Subject: RE: South Miami Attachments: City of South Miami See the attached e-mail. Let me know if you need anything else. JoLinda Herring Bryant Miller Olive One Biscayne Tower 2 South Biscayne Boulevard, Suite 1480 Miami, Florida 33131 Telephone: (305) 374 -7349 Fax: (305) 374 -0895 lj inda @bmolaw.com Page I of 2 TAX ADVICE DISCLOSURE: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any U.S, federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cant-tot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein. NOTICE TO RECIPIENT: This e-mail message is intended only for the individual or entity to which it is addressed and may contain confidential information and /or attachments that are legally privileged. If you are not the intended recipient, any review, use, dissemination, distribution or copying of this e-mail is strictly prohibited. If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone and delete this message. Please note that if this e-mail contains a forwarded message, an attachment, or is in reply to a prior message, some or all of the contents of this message may not have been produced by Bryant Miller Olive P.A. - - - -- Original Message---- - From: Luis Figueredo [maiito:lfigueredo @ngf- law.comj Sent: Monday, March 03, 2008 1:58 PM To: Jolinda Herring Subject: South Miami Jolinda, Please let me know when we can expect the documentation we discussed during our conference call on Thursday. Thank you. Luis 4/20/2010 Message Luis R. Figueredo, Nagin Gallop & Figueredo, P.A. 18001 Old Cutler Road, Suite 556 Palmetto Bay, Florida 33157 Telephone: (305)854-5353 Facsimile: (305)(854 -5351 LFioueredo@nof -law cote 4/20/2010 Page 2 of 2 Message Jolinda Herring From: Jolinda Herring Sent: Friday, February 29, 2008 10:05 AM To: Patti Garrett; mark.raymond @hkiaw.com Subject: City of South Miami Page I of 1 BMO had a call with the City of South Miami and the City Attorney to discuss the parking garage after review of the Lease Agreement. It was concluded that the Lease Agreement would cause the Loan/Bonds to be private activity bonds. The City has agreed to amend the lease to comply with the Qualified Management Contract rules. They expect to have it completed within the next 60 days. JoLinda Herring Bryant Miller Olive One Biscayne Tower 2 South Biscayne Boulevard, Suite 1480 Miami, Florida 33131 Telephone: (305) 374 -7349 Fax: (305) 374 -0895 iolinda @bmolaw.com . TAX ADVICE DISCLOSURE: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any U.S, federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein. NOTICE TO RECIPIENT: This e-mail message is intended only for the individual or entity to which it is addressed and may contain confidential information and /or attachments that are legally privileged. If you are not the intended recipient, any review, use, dissemination, distribution or copying of this e-mail is strictly prohibited. If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone and delete this message. Please note that if this e-mail contains a forwarded message, an attachment, or is in reply to a prior message, some or all of the contents of this message may not have been produced by Bryant Miller Olive P.A. 4/20/2010 Message Jolinda Herring From: Jolinda Herring Sent: Thursday, February 28, 2008 11:54 AM To: 'Imares @ngf- law.com' Cc: Bob Reid Subject: City of South Miami Attachments: 0028_999900_20080228_114539. pdf Tracking: Recipient Delivery lmares @ngf- law.com' Bob Reid Delivered: 2/28/2008 11:54 AM Page I of I Attached is IRS Revenue Procedure 97 -13 and a general explanation of the Revenue Procedure. Please do not hesitate to call me if you have questions. I will send an example contract under separate cover within the next day or two. JoLinda Herring Bryant Miller Olive One Biscayne Tower 2 South Biscayne Boulevard, Suite 1480 Miami, Florida 33131 Telephone: (305) 374 -7349 Fax: (305) 374 -0895 jolinda@bmolaw.com TAX ADVICE DISCLOSURE: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein. NOTICE TO RECIPIENT: This e -mail message is intended only for the individual or entity to which it is addressed and may contain confidential information and /or attachments that are legally privileged. If you are not the intended recipient, any review, use, dissemination, distribution or copying of this e-mail is strictly prohibited. If you have received this e-mail in error, please notify us immediately by return e -mail or by telephone and delete this message. Please note that if this e-mail contains a forwarded message, an attachment, or is in reply to a prior message, some or all of the contents of this message may not have been produced by Bryant Miller Olive P.A. 4/20/2010 Message Page 1 of 1 1 Jolinda Herring From: Betty Ramirez Sent: Wednesday, February 27, 2008 9:31 AM To: Jolinda Herring Subject: Luis Figueredo returned your call 305 -854 -5353 Betty Ramirez Bryant Miller Olive One Biscayne Tower 2 S. Biscayne Boulevard, Suite 1480 Miami, Florida 33131 (305) 374 -7349 (305) 374 -0895 (fax) bramirez@bmolaw.com NOTICE TO RECIPIENT: This e-mail message is intended only for the individual or entity to which it is addressed and may contain confidential information and /or attachments that are legally privileged. If you are not the intended recipient, any review, use, dissemination, distribution or copying of this e-mail is strictly prohibited. If you have received this e-mail in error, please notify us immediately by return e-mail or by telephone and delete this message. Please note that if this e-mail contains a forwarded message, an attachment, or is in reply to a prior message, some or all of the contents of this message may not have been produced by Bryant Miller Olive P.A. 4/20/2010