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14LEVESQUE LAW GROUP LLC 3380 Street Suite 202 Anchorage Alaska 99503 Phone 907 261-8935 Fax 206 309-0667 Email joe@levesquelawgroup.com September 16 2015 Kodiak Island Borough Alaska Alaska Municipal BondBank Re Kodiak Island Borough Alaska $6210000 General Obligation School Bond 2015 Series We have servedasco-bondcounsel to Kodiak Island Borough Alaska the Borough in connection withthe issuance ofthe above-referenced bond the 2015A Bond and in that capacity have examined such law and such certified proceedings and other documents as we have deemed necessary to render this opinion As to matters offact material to this opinion we have relied upon representations contained in the certified proceedings and other certificationsof public officials furnished to us without undertaking to verify the same by independent investigation The 2015A Bond is issued by the Borough pursuant to Resolution No FY2016- 05 the Resolution under and in accordance withtheConstitution and laws of the State 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 other sales or disclosure material relating to the issuance ofthe 2015A Bond or otherwise used in connection withthe 2015A Bond or the Alaska Municipal BondBank General Obligation Bonds 2015 Series Three the Bond Bank Bonds portion of the proceeds of which are being used to acquire the 2015A Bond or otherwiseused in connection with the 2015A Bond or the BondBank Bonds Under theInternal Revenue Code of 1986 as amended the Code the Borough is required to comply withcertain requirements after thedate of issuance of the 2015A Bond in order to maintain the exclusion oftheinterest on the 2015A Bond from gross income for federal income tax purposes including without limitation requirements concerning the qualified use of 2015A Bond proceeds and the facilities financed or refinanced with 2015A Bond proceeds limitations on investing gross 51466920 LEVESQUE LAW GROUP LLC Kodiak Island Borough Alaska Alaska Municipal BondBank September 16 2015 Page proceeds of the 2015A Bond in higher yielding investments in certain circumstances and the arbitrage rebate requirement to the extent applicable to the 2015A Bond The Borough hascovenanted in the Resolution to comply with those requirements but if the Borough fails to comply with those requirements interest on the 2015A Bond could become taxable retroactive to thedate of issuance ofthe 2015A Bond We have not undertaken anddo not undertake to monitor the Boroughs compliance with such requirements Based upon the foregoing as of thedate of initial delivery of the 2015A Bond to the purchaser thereof and full payment therefor it is our opinion that under existing law The Borough is duly organized and legallyexisting municipal corporation underthelaws oftheStateof Alaska The Loan Agreement between the Borough and the Alaska Municipal Bond Bank dated as of September 2015 relating tothe 2015A Bond has been duly authorized executed and delivered by the Borough and is valid and bindingobligation ofthe 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 the exercise of judicial discretion in appropriate cases The2015A Bond has been duly authorized and issued by the Borough and is issued infull compliance withthe provisions of the Constitution and laws ofthe State of Alaska and the ordinances and resolutionsofthe Borough relating thereto The2015A Bond constitutesvalid and binding general obligation ofthe Borough payable fromannual ad valoremtaxes to be levied without limitation as to rate or amount on all of the taxable property within the Borough except only to the extent that enforcement of payment may be limited by bankruptcyinsolvency orother laws affecting creditors rights and by the application of equitableprinciples and the exercise of judicial discretion in appropriate cases Assuming complianceby the Borough alter the date of issuance of the 2015A Bond with applicable requirements ofthe Code theinterest on the 2015A Bond 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 2015A Bond also is not an item of tax preference for purposes of the alternative minimum tax applicable to corporations interest on the 2015A Bond received bycorporations is to betaken into account in the computation of 51466920.1 LEVESQUE LAW GROUP LLC Kodiak Island Borough Alaska Alaska Municipal BondBank September 16 2015 Page adjusted current earnings for purposes ofthealternative minimum tax applicable to corporations interest on the 2015A Bond received by certain corporations may be subject to tax and interest on the 2015A Bond received by foreign corporations with UnitedStatesbranches may be subject to foreign branch profits tax Interest on the 2015A Bond is free from taxation by theStateof Alaska except for transfer estate and inheritance taxes and except to theextentinterest on the 2015A Bond received by corporations and taken into account in the computation of adjusted current earnings for purposes ofthealternative minimum tax applicable to corporations may affect the corresponding provisions oftheStateof Alaska corporate income tax We express no opinion regarding any other federalorstatetax consequences of receipt ofinterest on the 2015A Bond This opinion is given as of the date hereof and we assume no obligation to reviseor supplement this opinion to reflect any facts or circumstances that may hereafter come to our attention or anychanges in law that may hereafter occur We bring to your attention the factthatthe foregoingopinions are expressions of our professional judgment on thematters expressly addressed and do not constitute guarantees of result No attorney-clientrelationship has existed or exists between our firm and the Alaska Municipal Bond Bank in connection with the 2015A Bond or by virtue of this letter Respectfully submitted LEVESQUE LAW GROUP LLC ôzJ JosephLevesque 51466920