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91 <br /> of the Code and hold the 2024B Bonds as capital assets. A capital asset is generally an asset held for <br /> investment rather than as inventory or as property used in a trade or business. This summary also does not <br /> discuss the particular tax consequences that might be relevant to investors that are subject to special rules <br /> under the federal income tax laws. Special rules apply,for example,to trusts; estates;tax-exempt investors; <br /> foreign investors; banks, thrifts, insurance companies, regulated investment companies, or other financial <br /> institutions or financial service companies; brokers or dealers in securities, commodities or foreign <br /> currency;U.S.persons that have a functional currency other than the U.S.dollar;partnerships or other flow- <br /> through entities; real estate investment trusts, financial asset securitization investment trusts, subchapter S <br /> corporations;person subject to alternative minimum tax;persons who own the Bonds as part of a straddle, <br /> hedging transaction, constructive sale transaction or other risk-reduction transaction; persons who have <br /> ceased to be U.S. citizens or to be taxed as resident aliens; or persons who acquire the 2024B Bonds in <br /> connection with their employment or other performance of services. <br /> The following summary does not address all possible tax consequences. In particular, except as <br /> specifically described below, it does not discuss any estate, gift, generation skipping, transfer, state, local <br /> or foreign tax consequences.No ruling from the Internal Revenue Service(the"IRS")has been sought with <br /> respect to the statements made and the conclusions reached in the following summary, and there is no <br /> assurance that the IRS will agree with those statements and conclusions. For all these reasons, each <br /> prospective investor should consult with its tax advisor about the federal income tax and other tax <br /> consequences of the acquisition, ownership and disposition of the 2024B Bonds. <br /> As used herein, a"U.S. holder"is a beneficial owner of the 2024B Bonds who is a"United States <br /> person"and whose status as a U.S.holder is not overridden under the provisions of an applicable tax treaty. <br /> For these purposes, a"United States person" is a citizen or resident of the United States; a corporation or <br /> partnership that is created or organized in or under the laws of the United States or any of the fifty states or <br /> the District of Columbia, unless, in the case of a partnership, otherwise provided by the Treasury <br /> Regulations; an estate the income of which is subject to federal income taxation regardless of its source;or <br /> a trust if a court within the United States is able to exercise primary supervision over the administration of <br /> the trust and one or more U.S.persons have the authority to control all substantial decisions of the trust. <br /> NOTICE PURSUANT TO IRS CIRCULAR 230 <br /> This discussion was not intended or written to be used,and cannot be used by any taxpayer,for the <br /> purpose of avoiding penalties that may be imposed on the taxpayer. This discussion was written to support <br /> the promotion or marketing of the 2024B Bonds.Each taxpayer should seek advice based on the taxpayer's <br /> particular circumstances from an independent tax advisor. <br /> ORIGINAL ISSUE PREMIUM <br /> The 2024 Bonds maturing on October 1, (collectively, the "Premium Bonds") are being <br /> sold at an initial offering price in excess of the principal amounts payable at maturity. Under the Code,the <br /> difference between(a)the initial offering prices to the public(excluding bond houses and brokers)at which <br /> a substantial amount of each maturity of the Premium Bonds is sold and(b)the principal amount payable <br /> at maturity of such Premium Bonds constitutes "original issue premium". Original issue premium is not <br /> deductible for federal income tax purposes. <br /> For an owner of a Premium Bond, the amount of the original issue premium which is treated as <br /> having accrued over the term of such Premium Bond is reduced from the owner's cost basis of such <br /> Premium Bond in determining, for federal income tax purposes,the gain or loss upon the sale,redemption <br /> or other disposition of such Premium Bond(whether upon its sale,redemption or payment at maturity). <br /> 19 <br />