Overview of Private Activity Bond Financing and Incentives

This memorandum provides for tax-exempt Private Activity Bonds (previously known as Industrial Development Bonds) under the Internal Revenue Code of 1986, as amended (“I.R.C.”), including financing for Section 501 manufacturing facilities. Provide a brief description and overview of the fundraising. (c)(3) Certain "Exempt Entities" and Business Zone Non-Profit Organizations. The memorandum also describes "taxable bond" financing and other industrial location incentives that have emerged as an alternative to the more restrictive private activity bond program. Details of “Manufacture of Retail Securities, " " Section 501(c)(3 Entities), " " Exempt Entities, " and " Taxable Bonds" are contained in this Memorandum. Bond financing for 501(c)(3) organizations, schools, hospitals, and government agencies is specialized, and separate summaries on these subjects are available upon request. The information provided may indicate whether bond financing or other incentives are available in a particular case, how the transaction is structured and operated, what the benefits are, and what restrictions may be imposed. help determine whether, however, you should consult a bond attorney early on to determine if your project is eligible and to ensure that applicable legal requirements are met. Bond Lending What is Bond Lending? Bond financing takes the form of loans from local government agencies, often development agencies or companies ("Issuers"), or in some cases, leases or installment sales. State laws regarding bonds vary, but are available in most jurisdictions. Bonds issued by the issuer may be eligible to pay tax-free interest to investors under the IRC, so interest rates are low. Lower interest rates are passed on to consumersThe funds raised from the bonds will be used to purchase facilities that the issuer will lend to users or that the issuer will lease or sell to users. Bonds are very flexible in constructing their terms. B. Floating and Fixed Rates, Prepaid, Long and Short Term. Why use bond financing? Interest on qualifying private activity bonds is exempt from federal income tax (except for bonds of Section 501(c)(3) organizations, subject to alternative minimum tax). Generally subject to state income tax. Government bonds are issued. The main advantage of private activity bond financing is that the regular lending rate is significantly lower than traditional lending rates due to the tax exemption. Taxable bonds do not qualify as federally tax-exempt personal activity bonds, but they typically pay interest that is exempt from state income taxes in the issuing state and may offer other benefits. In some jurisdictions, ad valorem and sales tax exemptions are available through private activity bond or taxable bond financing. See Taxable Bonds and Other Incentives in this document. Issuing Private Activity Bonds is generally exempt from registration with the SEC and Blue Sky. A final important consideration is that public participation in funding may generate greater community interest and support for the funded project (the "Project"). How are bonds redeemed? While bond financing is generally only guaranteed by the user's creditworthiness and the credit enhancements provided by the user, the assets that the user can pledge for that purpose. or secured by other collateral. Users typically use bank letters of credit or other forms of "credit enhancement." B. Bond insurance to protect bonds issued for the facility. Credit enhancements make it easier for investors to sell bonds and get the lowest interest rates because investors look at and trust the financial strength of credit enhancements rather than the financial strength of users. However, the User's credit rating, financial situation and operational history must be sufficient for the Credit Enhancer to receive this type of funding. Who will buy government bonds? Bonds can be sold publicly or issued privately. Banks can buy bonds, but IThe RS rules will increase the interest rate on private activity bonds (other than certain Section 501(c)(3) bonds) held by banks (see “Placement of Bonds” in this document). Bonds can also be sold to institutional investors, mutual funds and sometimes individuals. Many banks and investment banks offer bond issuance and underwriting services (see Process Steps - Bond Issuance in this paper). Contents of this Memorandum. The remainder of this Memorandum addresses who may issue Private Activity Bonds, for what purposes, the restrictions and requirements imposed by state and federal law on the financing of Private Activity Bonds, and any such transactions. It describes the typical structures of , the steps required to complete them, and taxable bond financing. , tax and other incentives, and the role of bond attorneys. Fundable Project Types Production and processing facilities. “Small-spend” private activity bonds may be issued for property and facilities used in the manufacture, production, or processing of private property, and for site-related and ancillary office and other space (bonds not exceed 25% of income). may be used). ancillary use). At least 70% of proceeds from small issue bonds must be used to fund assets directly used in the manufacture, production, or processing of personal property (directly used assets are “core manufactured assets”). called). For example, assets used to store or transport raw materials or inventory are not central production facilities, but are often functionally linked to manufacturing processes. I.R.S. rules require companies wishing to use bonds for manufactured assets not to exceed the 25% limit on financing assets that are non-core manufactured assets and are only “ancillary investments” To this end, we may request that some of these portions of the Total Capital Project be excluded from funding.“Investments in real estate functionally related to the on-site manufacturing of goods and used for functions such as secondary warehousing, production offices, packaging, and shipping (although these functions represent a smaller proportion of the investment than (meaning) investments in core production facilities funded) are treated as “incidental costs” subject to a 25% cap. Section 501(c)(3) Nonprofit Entities. Private Activity Bonds can be issued to fund Section 501(c)(3) nonprofits such as schools, charities, and certain medical facilities. Certain tax-exempt private activity bonds for Section 501(c)(3) organizations may be designated as “eligible” for purchase by banks with full tax benefits. "Exempt" entity. Private Activity Bonds may also be issued to serve certain Eligible Projects such as: B. Certain multi-family rental housing projects, solid waste treatment facilities, hazardous waste facilities, water supply facilities, sewage facilities, electrical power facilities in certain areas, heating or cooling facilities in certain areas, airports and mass transit facilities; Public education facilities, green building and sustainable design projects, and certain freight transportation facilities are all exempt from the small spending limit. This category includes airports, docks, shipyards and mass transit facilities, which may be leased to private companies but must be owned by government entities. Rehabilitation Project. Pursuant to the redevelopment plan, the issuer will issue tax-exempt eligible redevelopment bonds for the acquisition, eviction, and redevelopment of property in designated areas designated as degraded for resale to individuals at market value. can be issued. The Notes are primarily collateralized against generally applicable taxes, including an increase in property taxes resulting from the appreciation resulting from the implementation of restructuring plans. Such bonds may take the form of "tax sharing bonds" or other tax increasing loans. Restricted Used Equipment and Buildings. Section 501(c)(3) Personal Activity Bonds, Excluding Bonds for Organizations and Qualifying Enterprise Zone Businesses, except for used buildings (and building fixtures purchased with buildings) to acquire previously used assets cannot be used for Other structures may be funded if sufficient eligible rehabilitation is implemented. 15% for buildings (and such integrated equipment) and 100% for other structures. Improper use. Federal law allows up to 5% of proceeds from private activity bonds to be used for non-capital purposes or other ineligible expenses, but applicable state laws may be more restrictive .When bond proceeds are used for issuance costs, they count against this 5%. Proceeds from Private Activity Bonds cannot be used to furnish aircraft, private luxury boxes, certain health club facilities, gaming facilities, or liquor stores. Widespread use of taxable bonds. Projects approved under state law may be issued as taxable bonds. State laws vary widely, but authorize taxable bonds for a variety of manufacturing and non-manufacturing projects, including warehouses, distribution, offices, research and development, utilities, services, retail, commercial, and medical facilities. Bond Issuers Non-Profit Organizations. An issuer may issue bonds for a project only if the project serves a public purpose, such as increasing employment opportunities, promoting commerce or industry, or improving the common good. Specific requirements vary by state law. State Law. Private activity bonds must be issued by a government agency. Nearly all states have approved bond financing, and the types of issuers and projects they can fund vary. Fundable costs often include preliminary studies, direct project costs, legal fees, financing and emissions costs, construction interest, and certain reserves. For illustration purposes, here are some of the issuers and projects available for funding in Georgia. Development Agency. A development agency established by law in every city and county in Georgia and operating in many areas may acquire, construct, renovate, expand, improve, or alter facilities, factories, factories, sewage and waste facilities. Private activity bonds can be issued to fund Funding machinery, equipment, or other assets that the operating company may wish to purchase or lease in connection with the operation of facilities within its territoryDevelopment agencies can issue taxable bonds to a wider range of facilities such as warehouses, office buildings, industrial parks, nursing homes and research and development facilities. No entity receives funding from a development agency unless it increases or maintains some degree of permanent employment in the jurisdiction. In Georgia, many regional development agencies have also been established. Downtown Development Agency. The Downtown Development Authority could also be activated in incorporated Georgia municipalities. The Downtown Development Authority may fund projects determined by the agency to advance the public interest for which it was created. However, inner city development authorities can only fund projects in designated inner city development areas. Other rights. Housing Boards, Resource Reuse and Development Boards, Waste Management Boards, and Hospital Boards may also exist or be activated in each county and may issue bonds. In addition, in about two-thirds of Georgian districts, an amendment to the Georgian Constitution created special bodies with the power to issue bonds. In either case, you should refer to the relevant legislation. Size Limit General. Taxable bonds can be issued without size restrictions. Federal law sets maximum size limits for small-issue manufacturing projects, Enterprise Zone projects, and some funding for Section 501(c)(3) organizations. Funds for tax-exempt eligible residential rental properties, sewage or solid waste facilities, water utilities, community power and gas facilities, hazardous waste facilities, community heating and cooling facilities, transportation facilities, and eligible remediation projects Offers are unlimited in size.$1,000,000 micro notes. Small value private activity bond projects are subject to a $1,000,000 or more capital expenditure cap. Certain cities or counties can issue private activity bonds up to $1,000,000 to fund part of a project, regardless of size. provided, however, that previously used petty issuances for this Project, or for certain other entities within the same political jurisdiction of this Project, or of a "Principal User" of this Project (or an "Affiliate" of such a "Principal User") 's private activity bond shall be used by: A proposed undisclosed additional activity bond to determine compliance with the $1,000,000 limit. The use of the terms “primary users” and “stakeholders” is explained below. Retail bonds up to $10,000,000. The $1,000,000 bond size limit may be extended to $10,000,000 at the issuer's option. While the bond itself cannot exceed $10,000,000, the amount of capital expenditure permitted in the same jurisdiction for any period of time is limited to $20 million (the “Capital Expenditure Limit”), which allows for larger You will be eligible for a successful project. To determine compliance with the Capital Expenditure Limit, the total amount of Private Activity Bond issuances described in the preceding paragraph must include the specifics made or payable during the three years prior to and three years after issuance of “Capital Expenditure” should be added. Private Activity Bonds (and in any manner other than paid out of the proceeds of such bond issuance). Private activity bonds are subsequently taxable if the investment limit is exceeded at any time. Capital investment of . "Capital Expenditure" is a broad concept that includes all expenditures that may be capitalized under any treatment under the Internal Revenue Code. Capital Expenditure Limits The capital expenditures that must be considered are related to the project or to entities within the same county or incorporated municipality where the primary user (or stakeholder) of the project is. , is caused by an individual. is the primary her user. (Must include capital expenditures and private activity bond issuances in both jurisdictions in certain cases where affiliated or integrated facilities are in adjacent jurisdictions.) Primary UserPrimary users include both users and tenants, subtenants, or others who have the right (quota or otherwise) to occupy 10% or more of a project. Value is declining year by year. Applying the 10% annual rent test, tax refunds and other escalation fees, maintenance costs for shared spaces, etc. should all count as rent, with complications such as contingent rent. Additionally, if you purchase a majority of the goods or services produced by the project in accordance with your contractual obligations, you may qualify as a primary user of the project without having a usage right. There can be multiple main her users in the project. concerned. For these purposes, Affiliate includes any company, entity, or individual to which you or another principal user is affiliated by virtue of greater than 50% ownership or a "managed group" relationship. For individuals, related parties include certain family members and trusts. Includes capital expenditures. In addition to the above, other private activity bonds (and related capital expenses) may be included in the project. Includes calculation of $1,000,000 or capital expenditure. In addition, any other private property used wholly or partly in the same building or other parts of the office strip, warehouses, etc. Activity bonds (and related capital expenditures). Must be included in the $1,000,000 or $20,000,000 calculation. Excludes lease expenses. One way to keep costs down for minor problem projects is equipment leasing. Expenditures on “real” leases of equipment from independent third parties in the leasing business do not count as capital expenditures. The option to purchase leased equipment can be exercised after the three-year statute of limitations has expired. Ask for our Memorandum “Requirements for Genuine Leases for Investment Purposes”. $40,000,000 limit. Small Issue Private Activity Bonds are eligible for a three-year trial along with other Private Activity Bonds (whether Small Issues Can be assigned to facilities regardless. Any period over $40,000,000. To this end, when Private Activity Bonds fund projects with multiple owners, Private Activity Bonds are prorated based on ownership. When a private activity bond funds projects for multiple users, the private activity bond is distributed among users based on usage. ARBITRAGE Arbitrage limit. Bonds are not tax exempt if they qualify as “arbitrage bonds”. Arbitrage rules are complex and only a brief overview is provided below. The Notes can reasonably assume that 5% or more than US$100,000 of the amount treated as income on the Notes will be used, directly or indirectly, to acquire or substitute higher yielding investments. If it is an arbitrage bond. Amounts treated as borrowed money may include amounts pledged to pay the borrowed money or depreciation or other amounts for which the borrowed money can reasonably be expected to be repaid. The term "investment" is broad and includes substantially any contract or asset to which income can be attributed. Exceptions apply to investment of earnings during certain temporary periods. This includes the temporary investment of money in bona fide debt service funds and waiting funds. There is a three-year transition period before the investment income is used to acquire or construct real estate. Amounts placed in a reasonably necessary reserve or replacement fund are generally not subject to investment return limits, provided that the reserve or replacement fund may not exceed 10% of the proceeds of the issuance . Arbitrage Rebate. Even if a bond complies with the arbitrage rules above, any arbitrage earnings in excess of the bond's yield must be returned to the federal government on a regular basis.Discount rules require periodic calculation and submission. However, there are limited exceptions to the rebate requirement of 18 months and 6 months. The ability to comply with relevant exemptions may affect the timing of a User's completion of a bond issuance. 18 months exemption. A waiver of repayment obligations applies if all gross earnings (excluding earnings paid to reasonably necessary reserves) are paid in accordance with the following schedule: At least 15% within 6 months. At least 60% within 12 months. 100% within 18 months (excluding reasonable withholdings issued within 30 months). 6 months exemption. A waiver of reimbursement repayment requirements applies if all gross earnings (excluding earnings paid to reasonably necessary reserves) have been used within his six months. Exception limit. Compliance with the composition, 18-month or 6-month exemption exempts the obligation to recover arbitrage from the creation of reasonably necessary reserves or arbitrage on bona fide debt servicing funds exceeding $100,000 annually. not. Other Restrictions Period of private activity bond financing. The average useful life of private activity bonds is limited by federal law to 120% of the average reasonably expected economic life of the projects funded. The average economic life should be weighed against the cost of each of the project components. The economic life is determined from the date of private activity bond issuance or the commissioning date of the facility, whichever is later. Midpoint living under the traditional ADR system of personal property and building benchmarks under Revenue Procedure 62-21 can be treated as a safe haven for determining economic longevity. Land parcels are generally not considered when determining the average.Specific cost recovery method. The deduction for cost recovery (depreciation) for properties (other than eligible residential rental properties) funded by Private Activity Bonds must be determined using the straight-line method under an alternative depreciation system. No Federal Warranty. Private Activity Bonds are not tax exempt if the principal or interest payment is directly or indirectly guaranteed, in whole or in part, by the United States or its agencies or entities. A bond is treated as federally insured if 5% or more of the proceeds are used for federally insured loans or investments in federally insured deposits or accounts. To allow investment of proceeds in U.S. Treasury debt securities and investment in bona fide debt service funds, reasonably necessary reserves, and funds to hold proceeds prior to first use; Exceptions are made. Speculative projects. To comply with several federal and state laws, assets funded by Private Activity Bonds must be identified with reasonable certainty prior to issuance. Generally, private activity bonds cannot be issued to finance projects or contingencies that have an indefinite duration, or for amounts substantially in excess of the amount needed for the project. issuance costs. No more than 2% of the proceeds of the Privacy Bond may be used to pay the costs associated with issuing the Bond. Additional costs can be paid from other sources. Repurposed. Repurposing an entity funded by a Private Activity Bond to a use for which such Bond could not have been issued will result in the loss of User's deductions for interest on debt service and tax liability or other consequences of the Bond. There is a possibility. AWARD Solicitation decisionThe first step in bond trading is usually obtaining an incentive resolution and approval from the issuer. This is sometimes called a formal letter of intent (“incentive”). It represents a basic agreement by the issuer to issue bonds for a planned project. Incentives should be obtained as early as possible in the planning process. The public purpose principle suggests that incentives should serve as a factor in the decision to locate a project in a particular jurisdiction. Incentives should therefore generally be obtained before a user enters into a binding contract for a project site or construction. However, if an incentive or other qualifying official letter providing funding is issued within 60 days of the costs being issued and the bond is issued within 18 months of the project going live, the bond will We can fund the cost. Loanable Expenses. Expenses incurred prior to incentives (other than certain contingency expenses such as research and planning) are not "eligible expenses" under federal law. Federal law requires that 95% of private activity bond proceeds, including income from investments in private activity bond proceeds, be applied to qualifying real estate expenses and depreciable assets through prior incentives. If project components are purchased by interested parties, certain requests must be made to determine if the costs are reasonable. In addition, those who have used the facility for 5% or more in the 5 years before the issuance of the private activity deposit (“Important users”) and who have received 5% or more of the revenue of the private activity deposit Generally, 5 years after issuance may not be an important user. For these purposes, "Affiliate" has the meaning given above and includes each Member and its partnerships, each Shareholder and its "Sub-Chapter S" companies. Expired. Incentives may or may not have an expiration date. In any event, Private Activity Bonds must be issued within three years of the formal letter of intent and within eighteen months of the date of acquisition or commissioning of the project.Business Form General. Because bond trading uses the issuer as an intermediary, the transaction takes a different form than traditional financial transactions. The exact form to use will depend on the wishes of the parties and local requirements. In each transaction, the issuer sells the bond and makes the proceeds available to the project. Common deals include his three types of loans, leases, and installment purchases. loan. Issuers may be legally permitted to lend bond proceeds to users for use in projects. When using this form, the user enters into a loan agreement with the issuer and typically submits a bond as evidence of the loan borrowing. The issuer pledges the loan agreement and promissory note as collateral for the note. In such transactions, the user takes ownership of the project. This is the simplest and most common arrangement. Lease. Most issuers can, but some need to own the funded project and lease it to users. When such forms are used, the project location is usually transferred to the issuer and the project is constructed or acquired on the issuer's behalf with the proceeds of the bond. Projects are leased to users who agree to pay the applicable rent on the principal and interest of the bond.The issuer transfers its rights under the lease agreement as collateral for the bond. Once the bond is paid, the user usually gets the project for a nominal purchase price. In some jurisdictions, value and/or excise taxes can be avoided by using a form of leasing of transactions. See Ad valorem Tax Incentives below. Installment sales. Installment sales transactions may also be used. This type of transaction is similar to a lease transaction in that the issuer takes ownership of the project. In exchange for renting the Project to you, you enter into an installment purchase agreement. Under this agreement, you agree to pay installments of the purchase price equal to the debt service of the Notes. Ownership of the project can be transferred to the user immediately or after payment of the deposit. User control over the project. In any arrangement, loan, lease, or sale, the user is generally entitled to depreciation, is responsible for insurance, taxes and maintenance, has freedom of design and construction, and is entitled to all practical projects. can be considered "owner". Purpose. During the term of the loan, the user basically has the right to dispose of the project as with a conventional loan. In addition, bond transactions can include restrictions and safeguards typically associated with traditional construction, commercial or corporate loans. credits in bonds. Regardless of the form of the transaction, neither the issuer nor the municipality or state generally extend credit for the bonds.Noteholders agree to the underlying obligations of User and any guarantees, mortgages, securities, insurance, letters of credit, or other instruments or credit enhancements that User may agree to be provided to pay the Notes. Keep in mind However, some jurisdictions have legal authority to support bond financing through limited tax liens. You should consult a bond attorney regarding such arrangements. PROCEDURE Bond Placement. After an incentive is obtained and a bond attorney determines that the transaction can reasonably be structured as a bond project, the user typically issues the bond through an investment bank or underwriter. Bonds can be issued privately, such as by investor groups or financial institutions, by mutual funds, or sold publicly. The I.R.C. Bank and other financial institutions have refused to deduct interest on money borrowed to purchase or hold tax-exempt private activity bonds that were previously subject to an 80% deduction. As a result, such institutions now charge high interest rates on private activity bonds. The only exceptions to this treatment are certain government bonds under $10,000,000 and Section 501(c)(3) corporate bonds. Disclosure documents are typically prepared when using bond funds or public auctions. Depending on the type and number of bondholders, a trustee may be appointed for issuance. Interest on privacy activity bonds is not tax exempt if held by a significant user of the projectlegal documents. Once the nature of the bond sale has been determined, the terms of the bond and related documents must be negotiated and agreed upon. A bond attorney prepares most of the documents required for a transaction. If a grant is awarded, project acquisition and construction can begin during this period, subject to the availability of funds. "TEFRA" Hearing. Federal law requires a “TEFRA” hearing to be held at least 14 days after the issuance of a public notice informing the community of the nature and location of the proposed privacy bond and project. After such hearings, both the issuer and a suitably elected official or legislative body having jurisdiction over the project must approve the Private Her Activity Bond. Verification and other procedures. States often require additional procedures before issuing bonds. For example, most bonds in Georgia require judicial review in a process involving the state, issuers, and users. Additional public notices must be published prior to this process. Both TEFRA and state procedures affect reporting dates. Volume cap allocation. Each Privacy Bond (not issued to a 501(c)(3) entity) must be issued within that state's total privacy bond size limit, and additional steps are required to receive state quota allocations . Depending on the state, you may have to compete for quota from state or local pools.Georgia allocation process. Georgia has established a statewide pool and applications are reviewed on a regular basis. The "Economic Development Portion" is divided into four terms and is available on a first-come, first-served basis to all Private Activity Bonds that meet the criteria of creating or maintaining at least one job for every $125,000 of bond funding. To apply for allocation, you must provide a copy of the inducement, a public certification of the TEFRA hearing and TEFRA approval, an opinion from an attorney, and a letter of commitment from the bond purchaser, placement agent, or underwriter. Filing and Filing Fees. Special projects require additional materials. Private Activity Bonds must be sold within a certain period of time after being awarded. Information report. In connection with the closing of the transaction, an information report detailing the Private Activity Bond, Issuer, User and Project must be submitted to the Internal Revenue Service. Taxable Bonds and Other Incentives Use of Taxable Bonds. Due to the various restrictions on the issuance of federal tax exempt personal activity bonds set forth herein, users may elect to fund some or all of their projects with bonds that do not qualify for federal tax exemption on interest. can. Such bonds may be exempt from income tax in the issuing country and may be exempt from ad valorem tax in certain jurisdictions if the issuer assumes ownership of the project. Such taxable bonds are free from most of the procedural requirements and material restrictions set forth in this memorandum, which apply to private activity bonds. If parts of your project are not eligible for a Privacy Bond, you can combine a Privacy Bond and a Taxable Bond to finance the entire project. Or if there is no privacy bond available for a particular project (e.g., non-production projects or $10,000,000 projects) or unavailable on favorable terms, taxable bonds may be an attractive alternative. Any municipality in Georgia can use a bond lease transaction to grant partial relief, and some municipalities can completely exempt projects from ad valorem taxes. Request a copy of our Memorandum of Understanding "Ad valorem Tax Exemption for IDB-Lease Transactions". To obtain such an exemption, the issuer sells the exempt or taxable bond to finance the facility it leases to the user, the lease payments amortize the bond, and the user receives purchase of the facility. Constitutional amendments and laws establishing government agencies in Georgia usually include provisions exempting government agency property from taxation to the same extent as state property. These amendments and by-laws may contain further provisions that exemptions do not apply to lessees of government property. For example, the General Development Agency Act, which applies to the most common types of issuers, contains such provisions. In such cases, it is necessary to determine the value of the lease and assess the appropriate taxes. Given the terms and other features of the lease, leasehold taxation is lower than freehold interest taxation. Taxes often start low and increase each year as the value of the call option increases. Some special laws made by local development agencies include general tax exemptions, not the language in which rents are taxable. In such cases, the inherited building rights may be completely tax-free. Funding Program. Georgia sponsors several grant programs to promote economic developmentMost grants, which may support private projects, are applied for and awarded through development agencies and other local government agencies. Land or facilities funded from the grant can be leased by the funding agency to a private company and purchased by the private company after the lease term expires. Grant programs include the Community Development Block Grant (CDBG), the Employment Incentive Program (EIP), and the Regional Economic and Business Assistance Program (REBA), each administered by the Georgia Department of Community Affairs (DCA) for economic development, Growth, Enterprise Program (EDGE) is managed. ) and a stock fund program administered by the OneGeorgia Authority. Such grants are typically pledged as part of the process of negotiating bonds, property taxes, and other incentives with local development boards or other local economic development agencies. Other Incentives. About two-thirds of Georgia's local governments have implemented "freeport" inventory tax exemptions ranging from 20% to 100%. State Enterprise Zones, Foreign Trade Zones and Opportunity Zones are located in specific regions, each with significant taxes and other incentives. Business parks and speculative buildings have been developed in many locations, and grants, loans and other services are available. Labor market profiles, recruitment, screening and training are available. Many development agencies and communities have set up creative funding mechanisms that allow them to offer additional special incentives such as: B. Attractive or discounted building lots, buildings for rent, and other services for projects. Georgia's QuickStart program offers free, customized employee training services to qualified companies. Bond Counsel A legal advisor familiar with municipal bond law must be appointed as bond counsel. The function of Bond Counsel is to structure and document transactions and provide an opinion on bond validity and tax status. Bond Advisor's fees are paid by the user out of bond earnings. Bond Attorneys may represent other parties or separately represent users, issuers, bond purchasers or underwriters.