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72 <br /> OTHER TAX CONSEQUENCES <br /> Ownership or transfer of, or the accrual or receipt of interest on, the 2020 Bonds may result in <br /> collateral federal, State of North Carolina, and other state or local tax consequences to certain taxpayers, <br /> including, without limitation, financial institutions, property and casualty insurance companies, certain <br /> foreign corporations doing business in the United States,certain S corporations with excess passive income, <br /> individual recipients of Social Security or Railroad Retirement benefits, taxpayers who may be deemed to <br /> have incurred or continued indebtedness to purchase or carry tax-exempt obligations, taxpayers who may <br /> be eligible for the federal earned income tax credit, and taxpayers subject to franchise, estate, inheritance, <br /> gift or capital gains taxes. Owners and prospective purchasers of the 2020 Bonds should consult their tax <br /> advisors as to any such possible tax consequences. Except to the extent covered in its legal opinion,Bond <br /> Counsel expresses no opinion regarding any such collateral tax consequences. <br /> Interest on the 2020 Bonds may or may not be subject to state or local taxation in jurisdictions other <br /> than North Carolina. Owners and prospective purchasers of the 2020 Bonds should consult their own tax <br /> advisors as to the status of interest on the 2020 Bonds under the tax laws of any such jurisdiction other than <br /> North Carolina. Bond Counsel will express no opinion as to any such matters. <br /> No assurance can be given that future legislation, including amendments to the Code or <br /> interpretations thereof, if enacted into law, or certain litigation or judicial decisions, if upheld, will not <br /> contain provisions or produce results which could, directly or indirectly, reduce the benefit of the <br /> excludability of interest on the 2020 Bonds from gross income for federal income tax purposes. <br /> The Internal Revenue Service (the "Service") has an ongoing program of auditing tax-exempt <br /> obligations to determine whether, in the view of the Service, interest on such tax-exempt obligations is <br /> includable in the gross income of the owners thereof for federal income tax purposes. No assurances can <br /> be given as to whether or not the Service will commence an audit of the 2020 Bonds. <br /> Interest paid on tax-exempt obligations, such as the 2020 Bonds, will be subject to information <br /> reporting in a manner similar to interest paid on taxable obligations. Although such reporting requirement <br /> does not, in and of itself, affect the excludability of interest with respect to the 2020 Bonds from gross <br /> income for federal income tax purposes, such reporting requirement causes the payment of interest with <br /> respect to the 2020 Bonds to be subject to backup withholding if such interest is paid to beneficial owners <br /> who (a) are not"exempt recipients," and(b) either fail to provide certain identifying information(such as <br /> the beneficial owner's taxpayer identification number) in the required manner or have been identified by <br /> the Service as having failed to report all interest and dividends required to be shown on their income tax <br /> returns. Generally, individuals are not exempt recipients, whereas corporations and certain other entities <br /> generally are exempt recipients. Amounts withheld under the backup withholding rules from a payment to <br /> a beneficial owner would be allowed as a refund or credit against such beneficial owner's federal income <br /> tax liability provided the required information is furnished to the Service. <br /> CONTINUING DISCLOSURE OBLIGATION <br /> In accordance with the requirements of Rule 15c2-12 promulgated by the Securities and Exchange <br /> Commission under the Securities Exchange Act of 1934 ("Rule 15c2-12"), the County has undertaken in <br /> the Trust Agreement to provide, or cause to be provided through the Trustee, to the Municipal Securities <br /> Rulemaking Board(the"MSRB"): <br /> (1) by not later than seven months after the end of each fiscal year, beginning with the fiscal <br /> year ending June 30, 2020,the audited financial statements of the County for such fiscal year,if available, <br /> prepared in accordance with Section 159-34 of the General Statutes of North Carolina,as it may be amended <br /> 18 <br />