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89 <br /> determining the annual adjusted financial statement income of applicable corporations (as defined in <br /> Section 59(k) of the "Code," as defined below) for the purpose of computing the alternative minimum tax <br /> imposed on corporations for tax years that begin after December 31,2022. <br /> The County has covenanted to comply with the provisions of the Internal Revenue Code of 1986, <br /> as amended (the "Code"), regarding, among other matters, the use, expenditure and investment of the <br /> proceeds derived from the sale of the 2025 Bonds and the timely payment to the United States of any <br /> arbitrage profit with respect to the 2025 Bonds. The County's failure to comply with such covenants could <br /> cause interest on the 2025 Bonds to be included in gross income for federal income tax purposes <br /> retroactively to the date of issuance of the 2025 Bonds. <br /> In addition to the matters addressed above, prospective purchasers of the 2025 Bonds should be <br /> aware that the ownership of tax-exempt obligations may result in collateral federal income tax <br /> consequences to certain taxpayers,including without limitation financial institutions,property and casualty <br /> insurance companies, certain S corporations, certain foreign corporations subject to the branch profits tax, <br /> corporations subject to the environmental tax,recipients of Social Security or Railroad Retirement benefits <br /> and taxpayers who may be deemed to have incurred or continued indebtedness to purchase or carry tax- <br /> exempt obligations. Prospective purchasers of the 2025 Bonds should consult their tax advisors as to the <br /> applicability and impact of such consequences. <br /> Other Matters. Bond Counsel will give its opinions in reliance upon certifications by County <br /> representatives and others as to certain facts relevant to the opinion. <br /> Bond Counsel's opinions do not address the tax-exempt status of payments on the 2025 Bonds <br /> derived from parties other than the County,even if those payments are denominated as interest with respect <br /> to the 2025 Bonds.Bond Counsel will express no other opinion regarding the federal or North Carolina tax <br /> consequences of the ownership of or the receipt or accrual of interest on the 2025 Bonds. <br /> Interest on the 2025 Bonds may or may not be subject to state or local taxation in jurisdictions other <br /> than North Carolina. Prospective purchasers of the 2025 Bonds should consult their own tax advisors as to <br /> the status of interest on the 2025 Bonds under the tax laws of any such jurisdiction other than North <br /> Carolina. <br /> ORIGINAL ISSUE PREMIUM <br /> The 2025 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 /> Bond Counsel's opinion will not specifically address any issues relating to the treatment of <br /> premiums paid on Premium Bonds. Owners of Premium Bonds should consult their tax advisors with <br /> respect to the tax consequences of owning or disposing of a Premium Bond. <br /> 18 <br />