OTHER-2024-032-Preliminary official statement

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r ('I i i is r I of the Code and hold the 2024B Bonds as capital assets . A capital asset is generally an asset held for investment rather than as inventory or as property used in a trade or business . This summary also does not discuss the particular tax consequences that might be relevant to investors that are subject to special rules under the federal income tax laws . Special rules apply, for example, to trusts ; estates ; tax- exempt investors ; foreign investors ; banks , thrifts , insurance companies , regulated investment companies, or other financial institutions or financial service companies ; brokers or dealers in securities , commodities or foreign currency; U . S . persons that have a functional currency other than the U . S . dollar; partnerships or other flow- through entities ; real estate investment trusts , financial asset securitization investment trusts , subchapter S I' corporations ; person subject to alternative minimum tax; persons who own the Bonds as part of a straddle, k hedging transaction, constructive sale transaction or other risk-reduction transaction ; persons who have ceased to be U . S . citizens or to be taxed as resident aliens ; or persons who acquire the 2024B Bonds in connection with their employment or other performance of services . , The following summary does not address all possible tax consequences . In particular, except as specifically described below, it does not discuss any estate, gift, generation skipping, transfer, state, local or foreign tax consequences . No ruling from the Internal Revenue Service (the "IRS ") has been sought with respect to the statements made and the conclusions reached in the following summary, and there is no assurance that the IRS will agree with those statements and conclusions . For all these reasons , each prospective investor should consult with its tax advisor about the federal income tax and other tax consequences of the acquisition, ownership and disposition of the 2024B Bonds . f , As used herein, a "U . S . holder" is a beneficial owner of the 2024B Bonds who is a "United States person" and whose status as a U . S . holder is not overridden under the provisions of an applicable tax treaty . For these purposes , a "United States person" is a citizen or resident of the United States ; a corporation or partnership that is created or organized in or under the laws of the United States or any of the fifty states or the District of Columbia, unless , in the case of a partnership , otherwise provided by the Treasury Regulations ; an estate the income of which is subject to federal income taxation regardless of its source ; or a trust if a court within the United States is able to exercise primary supervision over the administration of the trust and one or more U . S . persons have the authority to control all substantial decisions of the trust . NOTICE PURSUANT TO II2S CIRCULAR 230 4'7 This discussion was not intended or written to be used, and cannot be used by any taxpayer, for the purpose of avoiding penalties that may be imposed on the taxpayer . This discussion was written to support the promotion or marketing of the 2024B Bonds . Each taxpayer should seek advice based on the taxpayer ' s particular circumstances from an independent tax advisor . ORIGINAL ISSUE PREMIUM h The 2024 Bonds maturing on October 1 , (collectively, the "Premium Bonds ") are being L sold at an initial offering price in excess of the principal amounts payable at maturity . Under the Code , the difference between (a) the initial offering prices to the public (excluding bond houses and brokers) at which a substantial amount of each maturity of the Premium Bonds is sold and (b) the principal amount payable at maturity of such Premium Bonds constitutes " original issue premium" . Original issue premium is not deductible for federal income tax purposes . For an owner of a Premium Bond, the amount of the original issue premium which is treated as having accrued over the term of such Premium Bond is reduced from the owner ' s cost basis of such Premium Bond in determining, for federal income tax purposes , the gain or loss upon the sale, redemption ' c or other disposition of such Premium Bond (whether upon its sale, redemption or payment at maturity) . 19 ; ;