Agenda 05-21-24; 6-b - Adoption of the Final Financing Resolution Authorizing the Issuance of Installment Purchase Financing for Various Capital Investment Plan Projects

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90 preference item for purposes of the federal alternative minimum tax; however, such interest is taken into account in determining the annual adjusted financial statement income of applicable corporations (as defined in Section 59(k) of the "Code," as defined below) for the purpose of computing the alternative minimum tax imposed on corporations for tax years that begin after December 31,2022. The County has covenanted to comply with the provisions of the Internal Revenue Code of 1986, as amended (the "Code"), regarding, among other matters, the use, expenditure and investment of the proceeds derived from the sale of the 2024A Bonds and the timely payment to the United States of any arbitrage profit with respect to the 2024A Bonds.The County's failure to comply with such covenants could cause interest on the 2024A Bonds to be included in gross income for federal income tax purposes retroactively to the date of issuance of the 2024A Bonds. In addition to the matters addressed above,prospective purchasers of the 2024A Bonds should be aware that the ownership of tax-exempt obligations may result in collateral federal income tax consequences to certain taxpayers,including without limitation financial institutions,property and casualty insurance companies, certain S corporations, certain foreign corporations subject to the branch profits tax, corporations subject to the environmental tax,recipients of Social Security or Railroad Retirement benefits and taxpayers who may be deemed to have incurred or continued indebtedness to purchase or carry tax- exempt obligations. Prospective purchasers of the 2024A Bonds should consult their tax advisors as to the applicability and impact of such consequences. Tax Treatment of 2024B Bonds — Federally Taxable. In the opinion of Bond Counsel, under existing law,interest payments on the 2024B Bonds will be included in gross income for federal income tax purposes,but will be exempt from State of North Carolina income taxation. Other Matters. Bond Counsel will give its opinions in reliance upon certifications by County representatives and others as to certain facts relevant to the opinion. Bond Counsel's opinions do not address the tax-exempt status of payments on the 2024 Bonds derived from parties other than the County,even if those payments are denominated as interest with respect to the 2024 Bonds.Bond Counsel will express no other opinion regarding the federal or North Carolina tax consequences of the ownership of or the receipt or accrual of interest on the 2024 Bonds. Interest on the 2024 Bonds may or may not be subject to state or local taxation in jurisdictions other than North Carolina. Prospective purchasers of the 2024 Bonds should consult their own tax advisors as to the status of interest on the 2024 Bonds under the tax laws of any such jurisdiction other than North Carolina. FEDERAL TAX MATTERS RELATED TO THE TAXABLE 2024B BONDS The following is a summary of certain U.S. federal income tax consequences relating to the purchase, ownership and disposition of the taxable 2024B Bonds. It does not provide a complete analysis of all potential tax considerations relating to the purchase, ownership and disposition of the 2024B Bonds that may be relevant to investors in light of their particular investment or other circumstances. This summary is based on the provisions of the Code, the applicable Treasury Regulations promulgated or proposed under the Code(the"Treasury Regulations"),judicial authority and administrative rulings and practice,all of which are subject to change,possibly retroactively,or to different interpretation. This summary applies only to initial purchasers of the 2024B Bonds that are "U.S. holders" (as defined below), acquire the 2024B Bonds at their original issue price within the meaning of Section 1273 18