HomeMy WebLinkAboutSubmittal-Robin Jones Jackson-Backup DocumentsBRC K � d 2 lee. C% �- A(d ✓embei2 ! R� 15 /- P.u�� Subtiiiited into the public
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SQUIRE ®` Squire Patton Boggs (US) LLP
�� One Tampa City Center
PATTON BOGGS 201 N. Franklin Street, Suite 2100
Tampa, Florida 33602
O +1 813 202 1300
F +1 813 202 1313
squirepattonboggs.com
Alexandra M. MacLennan
T +1 813 202 1353
sandy.maclennan@squirepb.com
November 19, 2015
Victoria Mendez
City Attorney
Robin Jones Jackson
Senior Assistant City Attorney
City of Miami, Office of the City Attorney
444 S!W. 2nd Avenue, Suite 945
Miamil, Florida 33130
United States of America
Dear Ms. Mendez and Ms. Jackson. -
You have asked that we confirm certain matters regarding the expenditure of certain remaining
proceeds of the $80,000,000.00 City Of Miami, Florida Special Obligation Bonds, Series 2007
(Street and Sidewalk Improvement Program) ("Series 2007 Bonds").
In that regard you have provided to us the proposed City legislation (your agenda item Number
RE -9 for the November 19, 2015 City Commission meeting) in which the City authorizes the
reallocation of expenditures made to pay debt service on the Series 2007 Bonds. In effect, this
City legislation allocates all remaining original proceeds of the Series 2007 Bonds and all
unspent investment earnings on such proceeds through the date of expenditure (collectively, the
"Remaining Proceeds") to certain debt service payments made or to be made with respect to
the Series 2007 Bonds on July 1, 2015 and January 1, 2016, which debt service payments were
originally (or would be) paid from other funds of the City as specified in the City. legislation.
Additionally, the City legislation authorizes the redeployment of such other funds of the City
used or budgeted to make the debt service payment on July 1, 2015 and January 1, 2016 to
other projects contained in the City's capital improvement budget.
We understand that the City reasonably expected on the date of issuance of the Series 2007
Bonds to spend all of the proceeds of the Series 2007 Bonds within the applicable time frames
set forth in the applicable federal income tax regulations. We also understand that,
unexpectedly, the City has been unable to apply the Remaining Proceeds of the Series 2007
-.... ..Bonds tocapitalprojectsto. date... In.order.to.expend..the..proceeds. as expeditiously_as.feasible......
weagree that the proposed action as detailed in the City legislation is permitted and will result in
the Remaining Proceeds being treated as immediately expended under applicable federal
44 Offices in 21 Countries
Squire Patton Boggs (US) LLP is part of the international legal practice Squire Patton Boggs, which operates worldwide through a number of separate
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legal entities.
Please visit squirepattonboggs.com for more information.
010-8166-1987/1 /AMERICAS
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PRe �g on I I r'1 15� City Clerk
Squire Patton Boggs (US) LLP Victoria Mendez
Robin Jones Jackson
November 19, 2015
income tax regulations, specifically Treasury Regulations Section 1.148-6(d)(3)(ii)(A)(6). In .
addition, the City should complete a final federal arbitrage rebate report as soon as possible and,
in anylevent, by January 15, 2016.
Please let us know if you have any further questions or if we can be of further assistance.
Yoursjsincerely
cc: Todd Cooper, Esq.
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010-8166-,1987/1 /AMERICAS
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OR Req- #OWmtep WIXV15
City Hall
City of Miami
3500 Pan American
Drive
§q ° .° Miami, FL 33133
0
Legislation
www.miamigov.com
Resolution: R-15-0169
File Number: 14-01252
Final Action Date: 4/9/2015
A RESOLUTION OF THE MIAMI CITY COMMISSION, WITH ATTACHMENT(S), IN
0 ; r COMPLIANCE WITH RESOLUTION NO. R-07-0586, ADOPTED OCTOBER 11, 2007
o ("BOND RESOLUTION"), AND THE TAX COMPLIANCE CERTIFICATE, DATED AS
r a OF DECEMBER 5, 2007 ("TAX COMPLIANCE CERTIFICATE") FOR THE
° a $80,000,000.00 CITY OF MIAMI, FLORIDA SPECIAL OBLIGATION BONDS, SERIES
' 2007 i(STREET AND SIDEWALK IMPROVEMENT PROGRAM) ("SERIES 2007
° BONDS"); AUTHORIZING THE CITY MANAGER, THE CITY ATTORNEY, BOND
COUNSEL, DISCLOSURE COUNSEL, AND ALL OTHER NECESSARY OFFICIALS,
70� EMPLOYEES, AND AGENTS OF THE CITY OF MIAMI ("CITY") TO TAKE ALL
m ACTIONS REQUIRED IN CONNECTION WITH THIS CONTINUING COMPLIANCE
.9 RESOLUTION; MAKING AMENDMENTS TO PREVIOUS APPROPRIATIONS
RELATING TO THE CAPITAL FUND, THE DEBT SERVICE FUND, GENERAL FUND,
AND SPECIAL REVENUE FUNDS BUDGETS FOR THE CURRENT FISCAL YEAR
�-
2015 AND THE PREVIOUS FISCAL YEAR ENDING SEPTEMBER 30, 2014 TO
COMPLY WITH THE BOND RESOLUTION AND THE TAX COMPLIANCE
CERTIFICATE FOR THE SERIES 2007 BONDS; AND AMENDING THE CITY'S
FISCAL YEAR 2014-2015 MULTI-YEAR CAPITAL PLAN ADOPTED SEPTEMBER 9,
2014 ;PURSUANT TO RESOLUTION NO. 14-0322, AS SUBSEQUENTLY AMENDED
("PLAN"), FOR CAPITAL IMPROVEMENTS PROJECTS ("PROJECTS") AND
APPROPRIATIONS TO THOSE PREVIOUSLY LISTED IN THE PLAN, AND
REVISING AND AMENDING CURRENT APPROPRIATIONS AMONG PREVIOUSLY
APPROVED PROJECTS; FURTHER APPROPRIATING FUNDING FOR PROJECTS,
ALL AS INDICATED IN CONSOLIDATED EXHIBITS A AND B, ATTACHED AND
INCORPORATED; RATIFYING, APPROVING, AND CONFIRMING CERTAIN
NECESSARY ACTIONS BY THE CITY MANAGER AND DESIGNATED CITY
DEPARTMENTS IN ORDER TO UPDATE THE RELEVANT FINANCIAL CONTROLS
AND COMPUTER SYSTEMS IN CONNECTION THEREWITH.
WHEREAS, on December 5, 2007, the City of Miami ("City") issued $80,000,000.00 of Special
Obligation Bonds, Series 2007 (Street and Sidewalk Improvement Program) ("Series 2007 Bonds") to
(i) finance the costs of acquisition, construction, and improvements to certain roadways, streetscapes,
and related appurtenances within the City as described in the Bond Resolution defined below, (ii) fund
a deposit to the Reserve Fund for the Series 2007 Bonds, and (iii) pay costs of issuance for the Series
2007 Bonds; land
WHEREAS, Resolution No. R-07-0586, adopted October 11, 2007 ("Bond Resolution"), and the
related Tax Compliance Certificate, dated as of December 5, 2007 ("Tax Compliance Certificate"), for
the Series 2007 Bonds required that the remaining unspent proceeds, and any interest thereon, be
spent on or before December 5, 2012, or if not expended prior to December 5, 2012, then such
original issue proceeds remaining outstanding, and any interest thereon, would be used to pay
principal and interest on the Series 2007 Bonds; and
WHEREAS, in accordance with the Bond Resolution, the Tax Compliance Certificate, and the
City of Miami Page 1 of 6 File Id. 14-01252 (Version: 1) Printed On: 11/19/2015
B � g&j,42Ei.R - ffo%�m b�a2 t, tors end q
Fil�Nber: 14-OT252 Enactment Number: R-15-0169
Financial Guarantee Agreement dated as of December 5, 2007, the Series 2007 Bonds remain insured
by a financial guaranty insurance policy ("Bond Insurance Policy") and the Reserve Fund Requirement
for the Series 2007 Bonds remains fully funded by a debt service surety bond ("Surety Bond"), both
v issued by MBIA Insurance Corporation, as merged with National Public Finance Guarantee
Corporation (collectively, "MBIA"), and the City (a) has provided MBIA a copy of this Compliance
v� U Resolution and related agenda package for MBIA's records, and (b) will provide MBIA with a final
iJ approved copy of this Compliance Resolution and all attachments thereto after City Commission
¢,Dl approval; and
o E WHEREAS, as of the previous Fiscal Year ended September 30, 2014, the City has updated it's
E Y Ir ' Arbitrage Rebate Report for the Series 2007 Bonds pursuant to the Bond Resolution and the Tax
w Compliance Certificate, and no rebate amount is due to the U.S. Internal Revenue Service; and
.E .S
wWHEREAS, from the $80,073,810 of Series 2007 Bond proceeds deposited on December 5, 2007,
`) '' ° as of January 9, 2015, the City still has remaining in the Streets and Sidewalk Capital Fund Series
2007 Bonds original issue proceeds in the amount of $3,127,792 (allocated to municipal capital
improvement projects, but unspent) and unspent and unallocated interest earnings in the amount of
$4,090,103, totaling $7,217,895; and
WHEREAS, historically from the date of issuance of the Series 2007 Bonds for debt service
payments commencing January 1, 2008 through January 1, 2015 , the designated pledged revenues
for the Series 2007 Bonds; (Local Option Gas Taxes from the Revenue Object Line Item in the
General Fund, twenty percent (20%) of the Parking Surcharges in the Revenue Object Line item in the
General Fund, and eighty percent (80%) of the City's portion of the Transportation Surtaxes Special
Revenue Funds, being collectively the "Designated Revenues") have been previously transferred to
the Debt Service Fund for the Series 2007 Bonds for a total amount of $38,341,707 and the City has
previously paid (a) for the current Fiscal Year 2015 principal and interest in the total amounts of
$3,494,478 on January 1, 2015, and (b) for the Fiscal Year ended September 30, 2014, principal and
interest in the total amount of $3,457,578 on January 1, 2014 and interest only in the amount of
$1,764,478 on July 1, 2014, totaling $8,716,534 for all three (3) debt service payments; and
I
WHEREAS, for the current Fiscal Year 2015, the City's required 2015 debt service payments for
the Series 2007 Bonds have all been previously budgeted in and appropriated from the Debt Service
Fund pursuant to the City's Fiscal Year 2014-2015 Final Budget requirements authorized pursuant to
City Commission Resolution No. 14-0362, adopted September 23, 2014, as subsequently amended
from time to time ("Budget"); and
WHEREAS, also for the current Fiscal Year 2015, the City Commission has previously adopted the
City's Fiscal Year 2014-2015 Multi -Year Capital Plan pursuant to Resolution No. 14-0322, adopted
September 9; 2015, as subsequently amended by Resolution No. 14-0383, adopted September 29,
2014, Resolution No. 14-0445, adopted November 20, 2014, Resolution Nos. 15-0008 and 15-0012,
adopted January 8, 2015, and Resolution No. 15-0048, adopted February 12, 2015 (collectively, the
"Plan"); and
WHEREAS, accordingly, for the current Fiscal Year 2015, in order to comply with the City's
continuing covenants under the Bond Resolution and the Tax Compliance Certificate, and in
accordance with advice from Bond Counsel, the City now determines to: (1) recognize and reallocate
$1,995,839 of the remaining unspent proceeds and interest earnings of the Series 2007 Bonds as a
debt service payment attributable to such payment previously made on January 1, 2015; (2) recognize
and reallocate back to the Local Option Gas Taxes Revenue Object Line Item in the General Fund the
City of Miand I Page 2 of 6 File Id. 14-01252 (Version: 1) Printed On: 11/19/2015
F.R - l �iD �P.v�-be a
File Ndmber.' 1,Y-01252 Enactment Number: R -I5-0169
amount of $771,244, and to the Transportation Surtaxes Special Revenue Fund the amount of
$1,224,595, totaling $1,995,839 of the earlier General Funds and Special Revenue Funds, as
v applicable, triansferred to pay debt service payments on the Series 2007 Bonds on January 1, 2015;
j and (3) attribute the related General Fund and Special Revenue Fund revenues in the amount of
v $1,995,839 previously budgeted to make such required debt service payments to amend, re -budget,
reprogram, and re -appropriate such previous General Fund and Special Revenue Fund amounts as
necessary to the Streets and Sidewalk Capital Fund for municipal capital improvements projects
appropriations as part of the close-out processes for the remaining proceeds and interest on the
o E Series 2007 Bonds pursuant to the Plan, as set forth in Composite Exhibits A and B described below;
^a
and
c — WHEREAS, accordingly, for the Fiscal Year ended September 30, 2014, in order to comply with
a v the City's continuing covenants under the Bond Resolution and the Tax Compliance Certificate, and in
accordance with advice from Bond Counsel, the City now determines to: (1) recognize and reallocate
$5,222,056 of the remaining unspent proceeds and interest earnings of the Series 2007 Bonds as a
debt service payment attributable to such payments previously made on January 1, 2014 and July 1,
2014; (2) recognize and reallocate back to the Local Option Gas Taxes Revenue Object Line Item in
the General Fund the amount of $1,379,618, to the Parking Surcharges Revenue Object Line Item in
the General Fund the amount of $756,594, and to the Transportation Surtaxes Special Revenue Fund,
the amount of $3,085,844, totaling $5,222,056 of the earlier General Funds and Special Revenue
Funds, as applicable, transferred to pay debt service payments on the Series 2007 Bonds on January
1, 2014 and July 1, 2014; and (3) attribute the related General Fund and Special Revenue Fund
revenues, as, applicable, in the total amount of $5,222,056 previously budgeted to make such required
debt service payments to amend, re -budget, reprogram, and re -appropriate such previous General
Fund and Special Revenue Fund amounts as necessary to the Streets and Sidewalk Capital Fund for
municipal capital improvements projects appropriations as part of the close-out processes for the
remaining proceeds and interest on the Series 2007 Bonds pursuant to the Plan, as set forth in
Composite Exhibits A and B described below; and
WHEREAS, it is now also in the best interests of the City to revise and amend in the Plan certain
municipal capital improvement projects as set forth below and to select, revise and update certain
previous app 'I opriations to be reallocated within the City's Capital Fund for the Plan; and
WHEREAS, the previous appropriations remain authorized to continue previously approved
municipal capital improvements projects and with the amendments to municipal capital improvements
projects set forth below, are collectively hereinafter referred to as the "Projects", all as set forth on
Consolidated, Exhibits A and B, attached and incorporated; and
WHEREAS, it is now necessary in order to approve appropriations for existing sources of revenues
for current Fiscal Year 2015 and amend to prior Fiscal Year 2014 appropriations in Capital Funds
based on the following format:
Fund
30000
Community Redevelopment Area
Fund
31000
General Government
Fund
32000
Public Safety
Fund
33000
Disaster Recovery
Fund
34000
Public Facilities
Fund
35000
Parks & Recreation
Fund
36000
Streets & Sidewalks
Fund
37000
Sanitary Sewers
City of Miami I Page 3 of 6 File Id: 14-01252 ([version: 1) Printed On: 11/19/2015
i
A(o e m bP-2 1q, 9,06 Genl�4
r�a�.t � l `J
File Nu ber.' 14- 12528 Enactment Number: R-/5-0/69
Fund 38000 Storm Sewers
Fund 39000 Solid Waste
U Fund 39900 Mass Transit
Fund 98004 ARRA Others - Memo Only;
U
NOW, THEREFORE, BE IT RESOLVED BY THE COMMISSION OF THE CITY OF MIAMI,
FLORIDA:
-. Section 1. The recitals and findings contained in the Preamble to this Resolution are adopted by
reference and incorporated as if fully set forth in this Section.
Section 2. For the current Fiscal Year 2015, in order to comply with the City's continuing
covenants under the Bond Resolution and the Tax Compliance Certificate, and in accordance with
o advice from Bond Counsel, the City Commission hereby (a) authorizes the City Manager, City
Attorney, Bond Counsel, Disclosure Counsel, and all other necessary officials, employees and agents
of the City to: (1),recognize and reallocate $1,995,839 of the remaining unspent proceeds and interest
earnings of the Series 2007 Bonds as a debt service payment attributable to such payment previously
made on January 1, 2015; (2) recognize and reallocate back to the Local Option Gas Taxes Revenue
Object Line Item in the General Fund the amount of $771,244, and to the Transportation Surtaxes
Special Revenue Fund the amount of $1,224,595, totaling $1,995,839 of the earlier General Funds
and Special Revenue Fund, as applicable, transferred to pay debt service payments on the Series
2007 Bonds on January 1, 2015; and (3) attribute the related General Fund and Special Revenue
Fund revenues in the amount of $1,995,839 previously budgeted to make such required debt service
payments to amend, re -budget, reprogram, and re -appropriate such previous General Fund and
Special Revenue Fund amounts as necessary to the Streets and Sidewalk Capital Fund for municipal
capital improvements projects appropriations as part of the close-out processes for the remaining
proceeds and interest on the Series 2007 Bonds pursuant to the Plan, as set forth in Composite
Exhibits A and B described below; and (b) delegates to the City Manager or his/her designees the
authority to issue appropriate project and account numbers and to execute minor associated
re -appropriations as necessary to these funds to effectuate the above ongoing compliance intent.
I
Section 3,. For the Fiscal Year ended September 30, 2014, in order to comply with the City's
continuing covenants under the Bond Resolution and the Tax Compliance Certificate, and in
accordance with advice from Bond Counsel, the City Commission hereby (a) authorizes the City
Manager, the City Attorney, Bond Counsel, Disclosure Counsel, and all other necessary officials,
employees, and agents of the City to: (1) recognize and reallocate $5,222,056 of the remaining
unspent proceeds and interest earnings of the Series 2007 Bonds as a debt service payment
attributable to such payments previously made on January 1, 2014 and July 1, 2014; (2) recognize and
reallocate back to the Local Option Gas Taxes Revenue Object Line Item in the General Fund the
amount of $1,379,618, to the Parking Surcharges Revenue Object Line Item in the General Fund the
amount of $756,594, and to the Transportation Surtaxes Special Revenue Fund the amount of
$3,085,844, totaling $5,222,056 of the earlier General Funds and Special Revenue Funds, as
applicable, transferred to pay debt service payments on the Series 2007 Bonds on January 1, 2014
and July 1, 2014; and (3) attribute the related General Fund and Special Revenue Fund revenues, as
applicable, in'i the total amount of $5,222,056 previously budgeted to make such required debt service
payments to amend, re -budget, reprogram, and re -appropriate such previous General Fund and
Special Revenue Fund amounts as necessary to the Streets and Sidewalk Capital Fund for municipal
capital improvements projects appropriations as part of the close-out processes for the remaining
proceeds and interest on the Series 2007 Bonds pursuant to the Plan, as set forth in Composite
Exhibits A and B described below; and (b) delegates to the City Manager or his/her designees the
i
City of Miami Page 4 of 6 File /d. 14-01252 (version: 1) Printed On: 11/19/2015
o E
V.
2 �d X02 ieE.cr - l� +- 1 `l, sols
F Number 1�f-01252 Enactment Number: R-15-0169
authority to issue appropriate project and account numbers and to execute minor associated
re -appropriations as necessary to these funds to effectuate the above ongoing compliance intent.
Section 4. The City Manager, the City Attorney, Bond Counsel, Disclosure Counsel, and all
other officials, employees and agents of the City are hereby authorized{1} to take all actions required
in connection with this continuing compliance resolution.
Section 5. For the current Fiscal Year commencing October 1, 2014 and ending September 30,
2015:
(a) The Debt Service Funds for the Series 2007 Bonds are not increased or decreased as the
payments to be made in those funds are not changing. Transfers In to the Debt Service
Fund in the amount of $1,995,839 will be transferred from the Street Bond 2007 Series
Capital Fund (36100) instead of from the Local Option Gas Taxes Revenue Object Line
Item in the General Fund and the Transportation Surtaxes Special Revenue Funds; and
(b) The Streets and Sidewalk Capital Fund is increased by $1,995,839 to allow for Transfers
Out in that amount from the Local Option Gas Taxes Revenue Object Line Item in the
General Fund and the Transportation Surtaxes Special Revenue Fund. An adjustment will
be made in the Fiscal Year 2015 Midyear Appropriation to reallocate the transferred
amounts.
O
Section 6; For the previous Fiscal Year commencing October 1, 2013 and ending September 30,
2014: 1
(a) Expenditures in the amount of $5,222,056 are recognized as funding and attributed in the _
Local Option Gas Taxes Revenue Object Line in the General Fund in the amount of $1,379,618, in the
Parking Surcharges Revenue Object Line Item in the General Fund in the amount of $756,594, and
the Transportation Surtaxes Special Revenue Funds in the amount of $3,085,844, for the January 1,
2014 and July 1, 2014 debt service payments totaling $5,222,056; and
(b) Expenditures in the amount of $5,222,056 are recognized as funding and attributed in the
Debt Service Funds for the Series 2007 Bonds from the above General Funds and Special Revenue
Funds.
Section 7. The City's Fiscal Year 2014-2015 Multi -Year Capital Plan adopted September 9,
2014 pursuant to Resolution No. 14-0322, as subsequently amended (collectively, "Plan"), is further
amended to amend Projects and to revise current appropriations among previously approved Projects
as set forth in Consolidated Exhibits A and B, attached and incorporated.
Fund 31000 General Government $14,692,470.13
Fund 32000 Public Safety $12,994,208.61
Fund 33000 Disaster Recovery $ 2,205,820.26
Fund 34000 Public Facilities $32,450,712.19
Fund 35000 Parks & Recreation $57,550,745.01
Fund 36000 Streets & Sidewalks $85,407,078.53
11
City of Miami Page 5 of 6 File Id. 14-01252 (Version: 1) Printed On: 11/19/2015
Back gez leE. �1- �v►mbe� , /51 hkP/S
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File Number' 14-01252 Enactment Number: R-15-0169
x
Fund 37000 Sanitary Sewer $ 5,128,871.42
U Fund 38000 Storm Sewers $21,544,052.38
U Fund 39000 Solid Waste $ 1,185,773.71
I Fund 39900 Mass Transit $ 2,042,907.94
TOTAL $235,202,640.18
w "
y _ Section 8. Certain necessary actions by the City Manager and designated City Departments in
�° order to update the relevant financial controls and computer systems in connection with the Plan and
E o the Budget to implement the Projects and for continuing compliance with the Bond Resolution and the
0 o Tax Compliance Certificate for the Series 2007 Bonds are ratified, approved, and confirmed.
Section 9. This Resolution shall become effective immediately upon its adoption and signature by
the Mayor. {1}
Footnotes:
I
{1} if the Mayor does not sign this Resolution, it shall become effective at the end of ten calendar
days from the date it was passed and adopted. If the Mayor vetoes this Resolution, It shall become
effective immediately upon override of the veto by the City Commission.
City of Miand Page 6 of 6 File Id. 14-01252 (version: 1) Printed On: 11/19/2015
BW Dq F1 A b._Foe-
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fly
-o
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rta
From:
Perez, Ofelia on behalf of Alfonso, Daniel J.
Sent:
Wednesday, April 08, 2015 11:05 AM
To:
U
Gort, Wifredo (Commissioner); Hardemon, Keon (Commissioner); Sarnoff, Marc
(Commissioner); Carollo, Frank (Commissioner); Suarez, Francis (Commissioner)
�jCc:
Re alado, Tomas (Mayor); Alfonso, Daniel J.; Bravo, Alice; Casama or, Fernando;
Ihekwaba, Nzeribe; Castaneda, Frank; McQueen, James; Nelson, Ron; Carollo, Frank
(Commissioner -Office); Stiers, Melissa; Mendez, Victoria; Min, Barnaby, Hannon, Todd;
Hernandez, Julia D.; Arcia, Miriam; Rose, Christopher, Arteaga, Diana; Rodriguez, Monica
U; McCray, Edith; Menardy, Alicia T.; Gomez, Marta; Perez, Ofelia
Subject:
RE.7 - Additional Background Information
Attachments:,
Letter from Alexandra MacLennan dated April 7, 2015.pdf, Electronic Code of Federal
Regulations.pdf
Importance:
Good morning,
High
On behalf of the City Manager, attached for your consideration is additional background information regarding RE.7 to
be discussed ait the April 91h City Commission Meeting.
Thank you.
o fella E. 'Perez
Executive secretary to the Cltu Mawager
TelephoKt # (3057) 2570-5402
14- 01252- so,
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6Gcegr
Ana oY - Mliti 01
ffim InFaym(Af�01
Submitted into the public
record for item(s)
on D4 Dal - wJ- • city clerk
%3ftcK I 2 .9-110Vern Mp�
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PATTON BOGGS
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April 7, 2015
U
Victoria Mendez
City Attorney
Robin Jones Jackson
Senior Assistant City Attorney
City of Miami, Office of the City Attorney
444 S.W. 2nd Avenue, Suite 945
Miami, Florida 33130
United States of America
Dear Ms. Mendez and Ms. Jackson:
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Squire Patton Boggs (US) LLP
One Tampa City Center
201 N. Franklin Street, Suite 2100
Tampa, Florida 33602
0 +1813 202 1300
F +1 813 202 1313
squirepattonboggs.com
Alexandra M. MacLennan
T +1 813 202 1353
sandy.maclennan@squirepb.com
You have asked that we confirm certain matters regarding the expenditure of certain remaining
proceeds of the $80,000,000.00 City Of Miami, Florida Special Obligation Bonds, Series 2007
(Street and Sidewalk Improvement Program) ("Series 2007 Bonds").
In that regard you have provided to us the proposed City legislation (your agenda item Number
RE -7 for the April 9, 2015 City Commission meeting) in which the City authorizes the
reallocation of expenditures made to pay debt service on the Series 2007 Bonds. In effect, this
City legislation allocates all remaining original proceeds of the Series 2007 Bonds and all
unspent investment earnings on such proceeds through the date of expenditure (collectively, the
"Remaining Proceeds") to certain debt service payments made with respect to the Series 2007
Bonds in fiscal years 2014 and 2015, which debt service payments were originally paid from
otHer funds of the City as specified in the City legislation. Additionally, the City legislation
authorizes the redeployment of such other funds of the City used to make debt service
payments in fiscal years 2014 and 2015 to other projects contained in the City's capital
improvement budget.
We understand that the City reasonably expected on the date of issuance of the Series 2007
Bonds to spend all of the proceeds of the Series 2007 Bonds within the applicable time frames
setjforth in the applicable federal income tax regulations. We also understand that,
unexpectedly, the City has been unable to apply the Remaining Proceeds of the Series 2007
Bonds to capital projects to date. In order to expend the proceeds as expeditiously as feasible,
weagree that the proposed action as detailed in the City legislation is permitted and will result in
the Remaining Proceeds being treated as immediately expended under applicable federal
44 Offices in 21 Countries
Squire Patton Boggs (US) LLP is part of the international legal practice Squire Patton Boggs, which operates worlOwldelhrfluahe tw�yc
legal entities. JUUIi1IliCQ 1'1
record for ites) E. 7
Pleas) mvisit squirepattonboggs.com for more information. City Clerk
010.6056.7608/2/AMERICAS on
I
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A19-
IX Sqi ire Patton Boggs (US) LLP
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0
Victoria Mendez
Robin Jones Jackson
April 7, 2015
income tax regulations, specifically Treasury Regulations Section 1.148-6(d)(3)(ii)(A)(6). In
addition, the City should complete a final federal arbitrage rebate report as soon as possible and,
in 'any event, by June 5, 2015.
Please let us know if you have any further questions or if we can be of further assistance.
Yours sincerely
{ /�
I . %� Wl
Alexandra MacLennan
Todd Cooper, Esq.
010-8056-780812/AMERICAS
Submitted into the public
record for item(s) &F 7
on City Clerk 2
eCFR Code of Federal Regulations
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U ELECTRONIC CODE OF FEDERAL REGULATIONS
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e -CFR data is current as of April 3, 2015
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Title 26 –+ Chapter I –+ Subchapter A –+ Part 1 –+ §1.148-6
Title 26: Internal Revenue
PART 1—INCOME TAXES (CONTINUED)
§1.148-6 General allocation and accounting rules.
�Cl�yj /LPun�
Page 1 of 7
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(a) In general—(1) Reasonable accounting methods required. An issuer may use any reasonable,
consistently applied accounting method to account for gross proceeds, investments, and expenditures
of an issue.
(2) Bona fide deviations from accounting method. An accounting method does not fail to be
reasonable and consistently applied solely because a different accounting method is used for a bona
fide governmental purpose to consistently account for a particular item. Bona fide governmental
purposes may include special State law restrictions imposed on specific funds or actions to avoid grant
forfeitures.
(3) Absence of allocation and accounting methods. If an issuer fails to maintain books and records
sufficient to establish the accounting method for an issue and the allocation of the proceeds of that
issue, the rules of this section are applied using the specific tracing method. This paragraph (a)(3)
applies to bonds issued on or after May. 16, 1997.
(b) Allocation of gross proceeds to an issue—(1) One -issue rule and general ordering rules.
Except as otherwise provided, amounts are allocable to only one issue at a time as gross proceeds,
and if amounts simultaneously are proceeds of one issue and replacement proceeds of another issue,
those amounts are allocable to the issue of which they are proceeds. Amounts cease to be allocated
to an; issue as proceeds only when those amounts are allocated to an expenditure for a governmental
purpose, are allocated to transferred proceeds of another issue, or cease to be allocated to that issue
at retirement of the issue or under the universal cap of paragraph (b)(2) of this section. Amounts cease
to bei allocated to an issue as replacement proceeds only when those amounts are allocated to an
expenditure for a governmental purpose, are no longer used in a manner that causes those amounts
to be', replacement proceeds of that issue, or cease to be allocated to that issue because of the
retirement of the issue or the application of the universal cap under paragraph (b)(2) of this section.
Amounts that cease to be allocated to an issue as gross proceeds are eligible for allocation to another
issue: Under §1.148-10(a), however, the rules in this paragraph (b)(1) do not apply in certain cases
involving abusive arbitrage devices.
I
(2) Universal cap on value of nonpurpose investments allocated to an issue—(i) Application. The
rules in this paragraph (b)(2) provide an overall limitation on the amount of gross proceeds allocable to
an issue. Although the universal cap generally may be applied at any time in the manner described in
this paragraph (b)(2), it need not be applied on any otherwise required date of application if its
application on that date would not result in a reduction or reallocation of gross proceeds of an issue.
For this purpose, if an issuer reasonably expects as of the issue date that the universal cap will not
reduce the amount of gross proceeds allocable to the issue during the term of the issue, the universal
cap need not be applied on any date on which an issue actually has all of the following
characteristics—
Submitted into the publi��, -7record for items)
(amity Clerk
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(A) No replacement proceeds are allocable to the issue, other than replacement proceeds in a
bona fide debt service fund or a reasonably required reserve or replacement fund;
I (B) The net sale proceeds of the issue—
(1) Qualified for one of the temporary periods available for capital projects, restricted working
capital expenditures, or pooled financings under §1.148-2 (e)(2), (e)(3), or (e)(4), and those net sales
proceeds were in fact allocated to expenditures prior to the expiration of the longest applicable
temporary period; or
(2) were deposited in a refunding escrow and expended as originally expected;
I(C) The issue does not refund a prior issue that, on any transfer date, has unspent proceeds
allocable to it;
j(D) None of the bonds are retired prior to the date on which those bonds are treated as retired in
computing the yield on the issue; and
i(E) No proceeds of the issue are invested in qualified student loans or qualified mortgage loans.
�(ii) General rule. Except as otherwise provided below, amounts that would otherwise be gross
proceeds allocable to an issue are allocated (and remain allocated) to the issue only to the extent that
the value of the nonpurpose investments allocable to those gross proceeds does not exceed the value
of all outstanding bonds of the issue. For this purpose, gross proceeds allocable to cash, tax-exempt
bonds that would be nonpurpose investments (absent section 148(b)(3)(A)), qualified student loans,
and' qualified mortgage loans are treated as nonpurpose investments. The values of bonds and
investments are determined under §1.148-4(e) and §1.148-5(d), respectively. The value of all
outstanding bonds of the issue is referred to as the universal cap. Thus, for example, the universal cap
for an issue of plain par bonds is equal to the outstanding stated principal amount of those bonds plus
accrued interest.
I
(iii) Determination and application of the universal cap. Except as otherwise provided, beginning
with the first bond year that commences after the second anniversary of the issue date, the amount of
the universal cap and the value of the nonpurpose investments must be determined as of the first day
of each bond year. For refunding and refunded issues, the cap and values must be determined as of
each, date that, but for this paragraph (b)(2), proceeds of the refunded issue would become transferred
proceeds of the refunding issue, and need not otherwise be determined in the bond year in which that
date occurs. All values are determined as of the close of business on each determination date, after
giving effect to all payments on bonds and payments for and receipts on investments on that date.
(iv) General ordering rule for allocations of amounts in excess of the universal cap—(A) In
general. If the value of all nonpurpose investments allocated to the gross proceeds of an issue
exceeds the universal cap for that issue on a date as of which the cap is determined under paragraph
(b)(2)(iii) of this section, nonpurpose investments allocable to gross proceeds necessary to eliminate
that excess cease to be allocated to the issue, 'in the following order of priority—
(1) First, nonpurpose investments allocable to replacement proceeds;
I
(2) Second, nonpurpose investments allocable to transferred proceeds; and
(3) Third, nonpurpose investments allocable to sale proceeds and investment proceeds.
(B) Re -allocation of certain amounts. Except as provided in §1.148-9(b)(3), amounts that cease to
be allocated to an issue as a result of the application of the universal cap may only be allocated to
anot ier issue as replacement proceeds.
(C) Allocations of portions of investments. Portions of investments to which this paragraph (b)(2)
(iv) applies are allocated under either the ratable method or the representative method in the same
manner as allocations of portions of investments to transferred proceeds under §1.148-9(c).
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(v) Nonpurpose investments in a bona fide debt service fund not counted. For purposes of this
paragraph (b)(2), nonpurpose investments allocated to gross proceeds in a bona fide debt service
fund for an issue are not taken into account in determining the value of the nonpurpose investments,
and those nonpurpose investments remain allocated to the issue.
(c) Fair market value limit on allocations to nonpurpose investments. Upon a purchase or sale of a
nonpurpose investment, gross proceeds of an issue are not allocated to a payment for that
nonpurpose investment in an amount greater than, or to a receipt from that nonpurpose investment in
an amount less than, the fair market value of the nonpurpose investment as of the purchase or sale
date. For purposes of this paragraph (c) only, the fair market value of a nonpurpose investment is
adjusted to take into account qualified administrative costs allocable to the investment.
(d) Allocation of gross proceeds to expenditures—(1) Expenditures in generale—(i) General rule.
Reasonable accounting methods for allocating funds from different sources to expenditures for the
same governmental purpose include any of the following methods if consistently applied: a specific
c tracing method; a gross proceeds spent first method; a first -in, first -out method; or a ratable allocation
method.
(ii) General limitation. An allocation of gross proceeds of an issue to an expenditure must involve
a current outlay of cash for a governmental purpose of the issue. A current outlay of cash means an
outlay reasonably expected to occur not later than 5 banking days after the date as of which the
allocation of gross proceeds to the expenditure is made.
I
(iii) Timing. An issuer must account for the allocation of proceeds to expenditures not later than 18
months after the later of the date the expenditure is paid 'or the date the project, if any, that is financed
by the issue is placed in service. This allocation must be made in any event by the date 60 days after
the fifth anniversary of the issue date or the date 60 days after the retirement of the issue, if earlier.
This; paragraph (d)(1)(iii) applies to bonds issued on or after May 16, 1997.
I
(2) Treatment of gross proceeds invested in purpose investments—(i) In general. Gross proceeds
of an issue invested in a purpose investment are allocated to an expenditure on the date on which the
conduit borrower under the purpose investment allocates the gross proceeds to an expenditure in
accordance with this paragraph (d).
(ii) Exception for qualified mortgage loans and qualified student loans. If gross proceeds of an
issue are allocated to a purpose investment that is a qualified mortgage loan or a qualified student
loan; those gross proceeds are allocated to an expenditure for the governmental purpose of the issue
on the date on which the issuer allocates gross proceeds to that purpose investment.
i
(iii) Continuing allocation of gross proceeds to purpose investments. Regardless of whether gross
proceeds of a conduit financing issue invested in a purpose investment have been allocated to an
expenditure under paragraph (d)(2) (i) or (ii) of this section, with respect to the actual issuer those
gross proceeds continue to be allocated to the purpose investment until the sale, discharge, or other
disposition of the purpose investment.
,f (3) Expenditures for working capital purposes—(i) In general. Except as otherwise provided in this
paragraph (d)(3) or paragraph (d)(4) of this section, proceeds of an issue may only be allocated to
working capital expenditures as of any date to the extent that those working capital expenditures
exceed available amounts (as defined in paragraph (d)(3)(iii) of this section) as of that date (i.e., a
"proceeds -spent -last' method). For this purpose, proceeds include replacement proceeds described in
§1.148-1(c)(4).
i
ii) Exceptions—(A) General de minimis exception. Paragraph (d)(3)(i) of this section does not
apply; to expenditures to pay—
(1) Any issuance costs of the issue or any qualified administrative costs within the meaning of
§§1.148-5(e)(2) (i) or (ii), or §1.148-5(e)(3)(ii)(A);
(2) Fees for qualified guarantees of the issue or payments for a qualified hedge for the issue;
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x (3) Interest on the issue for a period commencing on the issue date and ending on the date that is
the later of three years from the issue date or one year after the date on which the project is placed in
U service;
(4) Amounts paid to the United States under §§1.148-3, 1.148-5(c), or 1.148-7 for the issue;
pl ,(5) Costs, other than those described in paragraphs (d)(3)(ii)(A) (1) through (4) of this section, that
do not exceed 5 percent of the sale proceeds of an issue and that are directly related to capital
v expenditures financed by the issue (e.g., initial operating expenses for a new capital project);
1(6) Principal or interest on an issue paid from unexpected excess sale or investment proceeds;
and
o— '(7) Principal or interest on an issue paid from investment earnings on a reserve or replacement
o fund that are deposited in a bona fide debt service fund.
I
i(B) Exception for extraordinary items. Paragraph (d)(3)(i) of this section does not apply to
expenditures for extraordinary, nonrecurring items that are not customarily payable from current
revenues, such as casualty losses or extraordinary legal judgments in amounts in excess of
reasonable insurance coverage. If, however, an issuer or a related party maintains a reserve for such
items (e.g., a self-insurance fund) or has set aside other available amounts for such expenses, gross
proceeds within that reserve must be allocated to expenditures only after all other available amounts in
that reserve are expended.
(C) Exception for payment of principal and interest on prior issues. Paragraph (d)(3)(i) of this
section does not apply to expenditures for payment of principal, interest, or redemption prices on a
prior issue and, for a crossover refunding issue, interest on that issue.
(D) No exceptions if replacement proceeds created. The exceptions provided in this paragraph (d)
(3)(ii) do not apply if the allocation merely substitutes gross proceeds for other amounts that would
have been used to make those expenditures in a manner that gives rise to replacement proceeds. For
example, if a purported reimbursement allocation of proceeds of a reimbursement bond does not
result in an expenditure under §1.150-2, those proceeds may not be allocated to pay interest on an
issue that, absent this allocation, would have been paid from the issuer's current revenues.
(iii) Definition of available amount—(A) In general. For purposes of this paragraph (d)(3), available
amount means any amount that is available to an issuer for working capital expenditure purposes of
the type financed by an issue. Except as otherwise provided, available amount excludes proceeds of
the issue but includes cash, investments, and other amounts held in accounts or otherwise by the
issuer or a related party if those amounts may be used by the issuer for working capital expenditures
of the type being financed by an issue without legislative or judicial action and without a legislative,
judicial, or contractual requirement that those amounts be reimbursed.
I
(B) Reasonable working capital reserve treated as unavailable. A reasonable working capital
reserve is treated as unavailable. Any working capital reserve is reasonable if it does not exceed 5
percent of the actual working capital expenditures of the issuer in the fiscal year before the year in
which the determination of available amounts is made. For this purpose only, in determining the
working capital expenditures of an issuer for a prior fiscal year, any expenditures (whether capital or
working capital expenditures) that are paid out of current revenues may be treated as working capital
expenditures.
(C) Qualified endowment funds treated as unavailable. For a 501(c)(3) organization, a qualified
endowment fund is treated as unavailable. A fund is a qualified endowment fund if—
i
(1) The fund is derived from gifts or bequests, or the income thereon, that were neither made nor
reasonably expected to be used to pay working capital expenditures;
I
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(2) Pursuant to reasonable, established practices of the organization, the governing body of the
,Y 501(c)(3) organization designates and consistently operates the fund as a permanent endowment fund
iu or quasi -endowment fund restricted as to use; and
U
(3) There is an independent verification that the fund is reasonably necessary as part of the
U organization's permanent capital.
i
0 I(D) Application to statutory safe harbor for tax and revenue anticipation bonds. For purposes of
section 148(f)(4)(B)(iii)(II), available amount has the same meaning as in paragraph (d)(3)(iii) of this
section, except that the otherwise -permitted reasonable working capital reserve is treated as part of
o E —' the available amount.
— (4) Expenditures for grants—(i) In general. Gross proceeds of an issue that are used to make a
grant are allocated to an expenditure on the date on which the grant is made.
E 0 j
c �(ii) Characterization of repayments of grants. If any amount of a grant financed by gross proceeds
of an issue is repaid to the grantor, the repaid amount is treated as unspent proceeds of the issue as
of the repayment date unless expended within 60 days of repayment.
i
(iii) Definition of grant. Grant means a transfer for a governmental purpose of money or property to
a transferee that is not a related party to or an agent of the transferor. The transfer must not impose
any obligation or condition to directly or indirectly repay any amount to the transferor. Obligations or
conditions intended solely to assure expenditure of the transferred moneys in accordance with the
governmental purpose of the transfer do not prevent a transfer from being a grant.
(5) Expenditures for reimbursement purposes. In allocating gross proceeds of issues of
reimbursement bonds (as defined in §1.150-2)) to certain expenditures, §1.150-2 applies. In allocating
gross proceeds to an expenditure to reimburse a previously paid working capital expenditure,
paragraph (d)(3) of this section applies. Thus, if the expenditure is described in paragraph (d)(3)(ii) of
this section or there are no available amounts on the date a working capital expenditure is made and
there are no other available amounts on the date of the reimbursement of that expenditure, gross
proceeds are allocated to the working capital expenditure as of the date of the reimbursement.
(6) Expenditures of certain commingled investment proceeds of governmental issues. This
paragraph (d)(6) applies to any issue of governmental bonds, any issue of private activity bonds
issued to finance a facility that is required by section 142 to be owned by a governmental unit, and any
portion of an issue that is not treated as consisting of private activity bonds under section 141(b)(9).
Investment proceeds of the issue (other than investment proceeds held in a refunding escrow) are
treated as allocated to expenditures for a governmental purpose when the amounts are deposited in a
commingled fund with substantial tax or other revenues from governmental operations of the issuer
and the amounts are reasonably expected to be spent for governmental purposes within 6 months
from the date of the commingling. In establishing these reasonable -expectations, an issuer may use
any reasonable accounting assumption and is not bound by the proceeds -spent -last assumption
generally required for working capital expenditures under paragraph (d)(3) of this section.
(7) Payments to related parties. Any payment of gross proceeds of the issue to a related party of
the payor is not an expenditure of those gross proceeds.
a
(e) Special rules for commingled funds --(1) In general. An accounting method for gross proceeds
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of anlissue in a commingled fund, other than a bona fide debt service fund, is reasonable only if it
satisfies the requirements of paragraphs (e)(2) through (6) of this section in addition to the other
requirements of this section.
(2) Investments held by a commingled fund—(i) Required ratable allocations. Not less frequently
.S
than as of the close of each fiscal period, all payments and receipts (including deemed payments and
_
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receipts) on investments held by a commingled fund must be allocated (but not necessarily distributed)
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among the different investors in the fund. This allocation must be based on a consistently applied,
Z 41-1
reasonable ratable allocation method.
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eCFR Code of Federal Regulations Page 6 of 7
i.cA (ii) Safe harbors for ratable allocation methods. Reasonable ratable allocation methods include,
without limitation, methods that allocate these items in proportion to either—
(A) The average daily balances of the amounts in the commingled fund from different investors
during a fiscal period (as described in paragraph (e)(4) of this section); or
(B) The average of the beginning and ending balances of the amounts in the commingled fund
from different investors for a fiscal period that does not exceed one month.
c — (iii) Definition of investor. For purposes of this paragraph (e), the term investor means each
. different source of funds invested in a commingled fund. For example, if a city invests gross proceeds
.o of an issue and tax revenues in a commingled fund, it is treated as two different investors.
0
° (3) Certain expenditures involving a commingled fund. If a ratable allocation method is used under
o paragraph (d) of this section to allocate expenditures from the commingled fund, the same ratable
allocation method must be used to allocate payments and receipts on investments in the commingled
fund under paragraph (e)(2) of this section.
i(4) Fiscal periods. The fiscal year of a commingled fund is the calendar year unless the fund
adopts another fiscal year. A commingled fund may use any consistent fiscal period that does not
exceed three months (e.g., a daily, weekly, monthly, or quarterly fiscal period).
(5) Unrealized gains and losses on investments of a commingled fund—(i) Mark -to -market
requirement for internal commingled funds with longer-term investment portfolios. Except as otherwise
provided in this paragraph (e), in the case of a commingled fund in which the issuer and any related
party own more than 25 percent of the beneficial interests in the fund (an internal commingled fund),
the fund must treat all its investments as if sold at fair market value either on the last day of the fiscal
year or the last day of each fiscal period. The net gains or losses from these deemed sales of
investments must be allocated to all investors of the commingled fund during the period since the last
allocation.
I
(ii) Exception for internal commingled funds with shorter -term investment portfolios. If the
remaining weighted average maturity of all investments held by a commingled fund during a particular
fiscal year does not exceed 18 months, and the investments held by the commingled fund during that
fiscal year consist exclusively of obligations, the mark -to -market requirement of paragraph (e)(5)(i) of
this section does not apply.
(iii) Exception for commingled reserve funds and sinking funds. The mark -to -market requirement
of paragraph (e)(5)(i) of this section does not apply to a commingled fund that operates exclusively as
a res erve fund, sinking fund, or replacement fund for two or more issues of the same issuer.
(6) Allocations of commingled funds serving as common reserve funds or sinking funds—(i)
Permitted ratable allocation methods. If a commingled fund serves as a common reserve fund,
replacement fund, or sinking fund for two or more issues (a commingled reserve), after making
reasonable adjustments to account for proceeds allocated under paragraph (b)(1) or (b)(2) of this
section, investments held by that commingled fund must be allocated ratably among the issues served
by the fund in
commingled accordance with one of the following methods—
I
(A) The relative values of the bonds of those issues under §1.148-4(e);
U
(B) The relative amounts of the remaining maximum annual debt service requirements on the
U
outstanding principal amounts of those issues; or
a
(C) The relative original stated principal amounts of the outstanding issues.
(ii) Frequency of allocations. An issuer must make any allocations required by this paragraph (e)
° d
(6) as of a date at least every 3 years and as of each date that an issue first becomes secured by the
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commingled reserve. If relative original principal amounts are used to allocate, allocations must also
°
be made on the retirement of any issue secured by the commingled reserve.
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PA lA N
[T.D. 8476, 58 FR 33532, June 18, 1993; 58 FR 44452, Aug. 23, 1993, as amended by T.D. 8538, 59 FR 24045,
May, 10, 1994; T.D. 8712, 62 FR 2304, Jan. 16, 1997; T.D. 8718, 62 FR 25512, May 9, 1997]
assistance?
Submitted into the public�
record for item(s)
on 01/'(X1 l�1/ �� City Clerk
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