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14LEVESQUE LAW GROUP LLC 3380 Street Suite 202 Anchorage Alaska 99503 Phone 907 261-8935 Fax 206 309-0667 February 20 2014 Email joelevesquelawgroup.com Kodiak Island Borough Alaska Alaska Municipal BondBank Re Kodiak Island Borough Alaska $22660000 General Obligation School Bond 2014 Series We have served as co-bondcounsel to Kodiak Island Borough Alaska the Borough in connection with the issuance of the above-referenced bond the 2014 Bond and in that capacity have examinedsuch law and such certified proceedings and other documents as we have deemed necessary to render this opinion As to matters offactmaterialto this opinion we have relied upon representations contained in the certified proceedings and other certifications of public officials furnished to us without undertaking to verify the same by independent investigation The2014Bond is issued by the Borough pursuant to Resolution No FY2014-24 the Resolution under and in accordance with the Constitution and laws of theState of Alaska and the ordinances and resolutionsof the Borough We have not been engaged to review and thus express no opinion concerning the completeness or accuracy of any official statement offering circular or othersales or disclosure material relating to the issuance of the 2014Bond or otherwise used in connection with the 2014Bond or the Alaska Municipal BondBank General Obligation Bonds 2014 Series One the Bond Bank Bonds portion of the proceeds of which are being used to acquire the 2014 Bond or otherwise used in connection with the 2014 Bond or the BondBank Bonds Under the Internal Revenue Code of 1986 as amended the Code the Borough is required to comply withcertain requirements after the date of issuance of the 2014Bond in order to maintaintheexclusion of the interest on the 2014 Bond from gross income for federal income tax purposes including without limitation requirements concerning the qualified use of 2014Bond proceeds and the facilities financed or refinanced with 2014Bond proceeds limitations on investing gross proceeds of the 2014Bond in higher yielding investments in certain circumstances and the arbitrage rebate requirement to theextent applicable to the 2014 BondThe LEVESQUE LAW GROUP LLC Kodiak Island Borough Alaska Alaska Municipal BondBank February 20 2014 Page Borough hascovenanted in theResolution to comply with those requirements but if the Borough fails to comply with those requirements interest on the 2014Bond could become taxable retroactiveto the date of issuance of the 2014 Bond We have not undertaken anddo not undertake to monitorthe Boroughs compliance with such requirements Based upon the foregoing as of the date of initial delivery of the 2014Bond to the purchaser thereof and full payment therefor it is our opinion that under existing law The Borough is duly organized and legally existing municipalcorporation under the laws of theState of Alaska The Loan Agreement between the Borough and the Alaska Municipal BondBank dated as of February 2014 relating to the 2014 Bond has been duly authorized executed and delivered by the Borough and is valid and binding obligation of the Borough enforceable against the Borough in accordance with its terms except only to theextent that enforcement of payment may be limited by bankruptcy insolvency or other laws affecting creditors rights and by the application of equitable principles and theexercise of judicial discretion in appropriate cases The 2014Bond has been duly authorized and issued by the Borough and is issued in full compliance with the provisions of the Constitution and laws of theState of Alaska and ordinances and resolutionsof the Borough relating thereto Assuming complianceby the Borough after the date of issuance of the 2014Bond with applicablerequirements of the Code the interest on the 2014Bond is excluded from gross income for federal income tax purposes and is not an itemoftax preference for purposes of the alternative minimum tax applicable to individuals however while interest on the 2014Bond also is not an item of tax preference for purposes of the alternative minimum tax applicable to corporations interest on the 2014 Bond received by corporations is to be taken into account in the computation of adjusted current earnings for purposes of the alternative minimum tax applicable to corporations interest on the 2014 Bond received by certain corporations may be subject to tax and interest on the 2014Bond received by foreign corporations with United States branches may be subject to foreign branch profits tax Interest on the 2014Bond is free from taxation by theState of Alaska except for transfer estate and inheritance taxes and except to the extent interest on the 2014Bond received by corporations and taken into account in the computation of adjusted current earnings for purposes of the alternative minimum tax applicable to corporations may affect the corresponding provisions of theState of Alaska corporate income tax LEVESQUE LAW GROUP LLC Kodiak Island Borough Alaska Alaska Municipal BondBank February 20 2014 Page We express no opinion regarding any other federalorstatetax consequences of receipt of interest on the 2014 Bond This opinion is given as of the date hereof and we assume no obligation to revise or supplement this opinion to reflect any facts or circumstances that may hereafter come to our attention or any changes in law that may hereafter occur We bring to your attention the factthat the foregoingopinions are expressions of our professional judgment on thematters expressly addressed anddo not constitute guarantees of result No attorney-clientrelationship has existed or exists between our firm and the Alaska Municipal BondBank in connection with the 2014Bond or by virtue of this letter Respecifully submitted LEVESQUE LAW GROUP LLC Joseph Levesque