SERIES TRUST AGREEMENT for AUSTIN TRUST, SERIES 10000 for $34,086,000 Variable Certificates, SERIES 10000 and $20,000 Inverse Certificates, SERIES 10000 Evidencing an Interest inCustodial Agreement • August 8th, 2008 • America First Tax Exempt Investors Lp • Finance services
Contract Type FiledAugust 8th, 2008 Company IndustryFederal and State Income Taxes: Bond Counsel rendered its opinion at the time of original issuance of the Underlying Bonds generally to the effect that, based on then existing laws, regulations and decisions and subject to certain conditions, interest on the Underlying Bonds is for federal income tax purposes is excludable from the “gross income” of the holders thereof, except for any holder who is treated pursuant to section 147(a) of the Code as a “substantial user” of the project or, a “related person” to such user. No opinion, however, was expressed regarding the treatment of the interest on the Underlying Bonds under the tax laws of the State of Texas.
SERIES TRUST AGREEMENT for AUSTIN TRUST, SERIES 10001 for $27,326,000 Variable Certificates, SERIES 10001 and $25,000 Inverse Certificates, SERIES 10001 Evidencing an Interest inCustodial Agreement • August 8th, 2008 • America First Tax Exempt Investors Lp • Finance services
Contract Type FiledAugust 8th, 2008 Company IndustryFederal and State Income Taxes: Bond Counsel rendered its opinion at the time of original issuance of the Underlying Bonds generally to the effect that, based on then existing laws, regulations and decisions and subject to certain conditions, the Underlying Bonds, as of their date of issuance, bear interest, unless the bondholder is a “substantial user” of the project or a “related person” to the “substantial user”, which is excludable from the gross income of the owner for purposes of federal income taxation and is excludable to the same extent from gross income and taxable net income of individuals, estates or trusts for purposes of State of Minnesota income taxation (but is subject to Minnesota franchise taxes imposed on corporations and financial institutions).