RESOLUTION 87-18789 RESOLUTION NO. 87-18789
A RESOLUTION OF THE CITY COMMISSION OF THE CITY OF
MIAMI BEACH, FLORIDA, AMENDING THE INTERLOCAL
AGREEMENT BY AND BETWEEN DADE COUNTY, FLORIDA, AND
THE CITY OF MIAMI BEACH, FOR THE FINANCING OF
EXPANSIONS AND IMPROVEMENTS TO THE MIAMI BEACH
CONVENTION CENTER BY ADDING TO SECTION 5, A
PARAGRAPH A, CONDITIONS FOR THIRD PARTY CONTRACTING
AND A PARAGRAPH B, CONDITIONS CONCERNING THE SERVICE
AMERICA, INC., CONCESSION AGREEMENT AND AUTHORIZING
THE MAYOR TO EXECUTE THE NECESSARY DOCUMENTS.
WHEREAS, the City of Miami Beach entered into an interlocal agreement with
Metropolitan Dade County in December of 1984 for the purpose of issuing a County Special
Obligation Bond for the expansion of the Miami Beach Convention Center; and
WHEREAS, pursuant to the change in the Tax Codes enacted by the Tax Reform Act
of 1986, the City must covenant that it will abide by the Act for third party contracts and
concession agreements.
NOW, THEREFORE BE IT DULY RESOLVED BY THE CITY COMMISSION OF THE CITY OF
MIAMI BEACH, FLORIDA, that:
1. The Interlocal Agreement by and between Dade County, Florida, and the City of
Miami Beach for the financing of the expansions and improvements to the Miami
Beach Convention Center is hereby amended to include the following additions to
Section 5 of the Agreement.
Section 5A. The City of Miami Beach, Florida, hereby covenants that it will not enter into
any contracts with a third party for the rental or use of the Miami Beach Convention Center
which contain provisions that are inconsistent with, contrary to or violative of the following
requirements of the Internal Revenue Service:
All contracts shall not exceed five years (including renewal options) and shall
contain the following provisions:
1. At least fifty percent (50%) of the compensation to any manager, other than
a governmental unit is based on a periodic, fixed-fee basis;
2. No amount of compensation is based on a share of net profits; and
3. The governmental unit owning the facility may terminate the contract
(without penalty) at the end of any three-year period.
Section 5B. The City of Miami Beach covenants that so long as any Dade County Special
Obligation Bonds (Miami Beach Convention Center Bonds) Series 1985 remain outstanding,
the fees paid to the City pursuant to the contract with Service America, Inc., shall not
exceed twenty-five percent (25%) of the annual principal and interest payments on all bonds
which remain outstanding with regard to the Miami Beach Convention Center.
2. The City of Miami Beach hereby authorizes the Mayor, in his absence, the Vice-Mayor,
to execute any documents for the above amendment to the Interlocal Agreement.
3. The above additions to the Interlocal Agreement constitute the second amendment to
the Agreement.
PASSED and ADOPTED this .18th day of March 1987.
c
r Ce Mayor
Attest:
City Clerk
APPROVED AS TO FORM:
4,71 .
2, tgat,tie
Legal Department
Dated 2-1447
LANGUAGE FOR INTERLOCAL AGREEMENT
The City covenants that it will not enter into any
contracts with a third party for the rental or use of the
Miami Beach Convention Center which contain provisions that
are inconsistent with, contrary to or violative of the
following requirements of the Internal Revenue Service :
All contracts shall not exceed five years (including
renewal options ) and shall contain the following provisions :
1 . At least fifty ( 50% ) percent of the compensation
to any manager other than a governmental unit is on a periodic,
fixed-fee basis ;
2 . No amount of compensation is based on a share of
net profits ; and
3 . The governmental unit owning the facility may
terminate the contract (without penalty) at the end of any
three-year period.
The City covenants that so long as any Dade County Special
Obligation Bonds (Miami Beach Convention Center Bonds ) Series
1985 remain outstanding, the fees paid to the City pursuant
to the contract with Service America, Inc. shall not exceed
twenty-five ( 25% ) percent of the annual principal and interest
payments on all bonds which remain outstanding with regard
to the Miami Beach Convention Center.
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SUMMARY OF THE LAW
BACKGROUND
The purpose of this summary is to explain to you the
practical reasons for the two covenants required by the County
from the City. The Memorandum of Law prepared by Kutak Rock
& Campbell after consultation with tax attorneys of my firm
(the "Memo" ) covers the technical IRS provisions. I hope
to provide you with an analysis in lay terms.
The Tax Reform Act of 1986 eliminated tax-exempt financing
for convention centers through the issuance of private activity
bonds. This is significant since a facility owned by a
government entity which is used by the private sector to
such an extent that it would not be eligible for tax-exempt
financing as a governmental facility would no longer be
eligible for tax-exempt financing. Moreover, it tightened
the test which the IRS utilizes to determine whether bonds
will be traditional governmental bonds or private activity
bonds. As the Memo points out, the percentage of private
use permitted for a governmental facility was reduced from
twenty-five ( 25% ) percent to ten (10% ) percent. When the
County issued the original bonds in 1985 (the "1985 Bonds" ) ,
the test which we applied to the contracts at the Convention
Center was twenty-five ( 25% ) percent. If the current ten
(10% ) percent rule was in effect at that time, the bonds
would not have qualified as governmental bonds.
In order to assist a governmental entity which finances
one of its facilities through the issuance of tax-exempt
bonds such as a convention center, the IRS has developed
guidelines which, if followed, would preserve the governmental
character of the facility. The guidelines set forth certain
provisions which must be included in all contracts with private
entities with regard to the use of the facility. Those
guidelines are set forth verbatim in the covenant which we
are asking the City to give in the Interlocal Agreement.
ADVANCE REFUNDING
The Tax Reform Act of 1986 includes a transition rule
for advance refundings of governmental bonds. As you know,
the County is currently planning to refund a portion of the
1985 Bonds which at the time of their issuance were classified
as governmental bonds. The County will receive approximately
$2 million in present value savings at the time of the
refunding which will be available to the City for the
construction and expansion of the Convention Center. The
transition rule provides that the twenty-five ( 25% ) percent
test will be utilized instead of the ten (10% ) percent test
to determine whether the 1985 Bonds are still governmental
bonds and whether it is reasonable to assume that they will
remain governmental bonds until paid off or refunded. As
a result, it is important for the City to maintain the
governmental status of the 1985 Bonds in order to qualify
for the advance refunding. The current financing contemplates
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that the 1985 Bonds will be paid off or defeased by 1992 .
In order to maintain the governmental status of the
1985 Bonds , the City must enter into the two covenants which
I have presented to you for inclusion in the Interlocal
Agreement. By complying with those two covenants, the City
will assure the County that the 1985 Bonds will not be deemed
to be private activity bonds as a result of any current or
future contracts between the City and users of the facility.
The first covenant merely requires the City to comply
with current law. So long as the City enters into contracts
with users of the Convention Center which are not contrary
to, inconsistent with or violative of the IRS guidelines,
the 1985 Bonds will maintain their governmental status.
Since the City has already entered into a contract for
the concession portion of the facility which is not within
the - guidelines of the IRS, it is important for the City to
limit the amount of money it receives from the concession
contractor while the 1985 Bonds are outstanding. As long
as the amount of money collected by the City from the
contractor annually is less than twenty-five (25%) percent
of the annual debt service on all bonds issued and outstanding
at that time, the 1985 Bonds will retain their governmental
status in spite of the concession contract.
From our discussions with Norman Litz, it appears that
neither one of these covenants will have an adverse effect
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on the City. The contracts typically used by the City for
events such as the Boat Show, Home Show, etc. are within
the IRS guidelines He did mention, however, that he was
considering an arrangement with an electrical contractor
which would require all private users to contract with the
electrical contractor. We advised him that such a contract
and similar contracts (telephone ) may violate the IRS
provisions and that he should seek advice before entering
into such a contract. As a practical matter, therefore,
the first covenant requiring the City to include certain
provisions in its long term contracts (less than five years )
will not affect the operation of the Convention Center.
With regard to the Service America Contract, Norman
Litz advised us that he estimated that by the year 1995 the
concession contract may be generating over $1 million per
year in revenues to the City. Until that time he anticipates
the • amount will be less than $1 million. The current debt
service for the bonds is approximately $4 . 8 million. The
Underwriter has indicated that the debt service will remain
approximately the same after the refunding and the new money
issue. As a result, the City would only jeopardize the
governmentalstatus of the 1985 Bonds if it were to collect
more than $1.2 million per year from the Service America
Contract while the 1985 Bonds are outstanding. Since the
bonds are scheduled to be def eased or redeemed by 1992,
the covenant by the City not to collect more than twenty-five
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( 25% ) percent of the annual debt service is not an important
factor. By the time the City expects to receive an amount
of money which may come close to twenty-five ( 25% ) percent
of its annual debt service, the 1985 Bonds should be paid
off and def eased.
I hope that the foregoing Summary is helpful to you.
If you would like to discuss the matter further, please feel
free to contact me at your convenience.
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ORIGINAL
RESOLUTION NO. 87-18789
(Amending the Interlocal AgiE by and
between Dade County, Florida, and the City
of Miami Beach, for the financing of ex-
pansJons and improvements to the Miami Bch,
Convention Center by adding to §5,
aara-
graph A, conditions for third party con-
tracting and a paragraph B, conditions
concerning the Service America, Inc. , con-
cession agreement and authorizing the
Mayor to execute the necessary documents)