§ 2049-nn. Exemption from taxes, assessments and certain fees. 1. It
is hereby determined that the creation of the authority and the carrying
out of its corporate purposes is in all respects for the benefit of the
people of the counties and the state and is a public purpose and the
authority shall be regarded as performing a governmental function in the
exercise of the powers conferred upon it by this title and shall not be
required to pay any taxes or assessments upon any property owned by it
or under its jurisdiction, control or supervision or upon its
activities, income and operations, or any filing, recording or transfer
fees or taxes in relation to instruments filed, recorded or transferred
by it or on its behalf provided, however, that the authority shall
annually pay a sum in lieu of taxes to each of the municipalities in
which any real property owned by or under its jurisdiction, control or
supervision of the authority are located in an amount equal to the taxes
and assessments which would have been levied upon such real property in
an unimproved state had such real property been owned by a person whose
real property is subject to taxation. The construction, use, occupation
or possession of any property owned by the authority or the counties,
including improvements thereon, by any person or public corporation
under a lease, lease and sublease or any other agreement shall not
operate to abrogate or limit the foregoing exemption, notwithstanding
that the lessee, user, occupant or person in possession shall claim
ownership for federal income tax purposes. Mortgages made or financed,
directly or indirectly, by the authority shall be exempt from the
mortgage recording taxes imposed by article eleven of the tax law.

2. Any bonds issued pursuant to this title together with the income
therefrom as well as the property of the authority shall be exempt from
taxes, except for transfer, and estate and gift taxes. The state hereby
covenants with the purchasers and with all subsequent holders and
transferees of bonds issued by the authority pursuant to this title, in
consideration of the acceptance of any payment for the bonds, that the
bonds of the authority issued pursuant to this title and the income
therefrom and all revenues, moneys, and other property pledged to secure
the payment of such bonds shall at all times be free from taxation,
except for transfer, and estate and gift taxes.