Section 2041-M. 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  participating  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 acquired or 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. The construction,
  use,  occupation or possession of any property owned by the authority or
  any participating county, 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. The authority shall be deemed a public authority
  for the purposes of section four hundred twelve of the real property 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 estate or gift  taxes  on  such  bonds  and  taxes  on
  transfers.  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 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 estate or gift taxes on such bonds  and  taxes
  on transfers.