Board Of Aldermen - Agenda - 11/24/2020 - P23
Nashua Performing Arts Center -- NMTC Term Sheet Confidential
October 14, 2020
(c) that the lease should constitute a true lease for federal income tax
purposes; ;
(d) that cach of the QLICI Loans and Fund Loan should constitute true debt
for federal income tax purposes;
(¢) an economic substance opinion; and
(f) such other appropriate opinions as requested by Investor and CDE after
review of the structure and underlying transaction documentation.