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91 <br /> taxes. Interest on the 2026A Bonds is not a separate tax preference item for purposes of the federal <br /> alternative minimum tax, but interest may be taken into account in computing the alternative minimum <br /> income tax on certain corporations. Upon the issuance of the Bonds, Bond Counsel expects to deliver an <br /> opinion substantially in the form attached as Appendix E. <br /> The County has covenanted to comply with the provisions of the Code regarding, among other <br /> matters,the use,expenditure and investment of the proceeds derived from the sale of the 2026A Bonds and <br /> the timely payment to the United States of any arbitrage profit with respect to the 2026A Bonds. The <br /> County's failure to comply with these covenants could cause interest on the 2026A Bonds to be included <br /> in gross income for federal income tax purposes retroactively to the date of issuance of the 2026A Bonds. <br /> Other Tax Consequences. In addition to the matters addressed above, prospective purchasers <br /> should be aware that the ownership of tax-exempt obligations such as the 2026A Bonds may result in <br /> collateral federal income tax consequences to certain taxpayers, including without limitation financial <br /> institutions,property and casualty insurance companies,certain S corporations,certain foreign corporations <br /> subject to the branch profits tax,corporations subject to the environmental tax,recipients of Social Security <br /> or Railroad Retirement benefits and taxpayers who may be deemed to have incurred or continued <br /> indebtedness to purchase or carry tax-exempt obligations. Prospective purchasers of the 2026A Bonds <br /> should consult their tax advisors as to the applicability and impact of such consequences. <br /> Basis and Limits of the Opinion. Bond Counsel will give its opinion in reliance upon certifications <br /> by County representatives and others as to certain facts relevant to the opinion. <br /> Bond Counsel's approving legal opinion expresses Bond Counsel's professional judgment as to the <br /> legal issues explicitly addressed in the opinion. By rendering a legal opinion, an opinion giver does not <br /> become an insurer or guarantor of that expression of professional judgment,of the transaction opined upon, <br /> or of the future performance of parties to the transaction.Additionally,the rendering of an opinion does not <br /> guarantee the outcome of any legal dispute that may arise out of the transaction, and a bond opinion is not <br /> a statement (either expressly or by implication) concerning the marketability, value, or likelihood of <br /> payment of the 2026A Bonds, or the suitability of the 2026A Bonds as an investment for any owner. <br /> Bond Counsel has not been engaged to investigate the County's operations or condition or the <br /> County's ability to provide for payments on the 2026A Bonds. Bond Counsel will express no opinion(1) <br /> as to the County's financial condition or its ability to provide for payments on the 2026A Bonds, or(2) as <br /> to the accuracy, completeness or fairness of any information that may have been relied on by anyone in <br /> deciding to purchase 2026A Bonds, including this Official Statement. In this transaction, Bond Counsel <br /> serves only as bond counsel to the County,and does not represent any purchaser or holder of 2026A Bonds. <br /> Bond Counsel's opinions do not address the tax-exempt status of payments on the 2026A Bonds <br /> derived from parties other than the County,even if those payments are denominated as interest with respect <br /> to the 2026A Bonds. Bond Counsel will express no other opinion regarding the federal or North Carolina <br /> tax consequences of the ownership of or the receipt or accrual of interest on the 2026A Bonds. <br /> Interest on the 2026A Bonds may or may not be subject to state or local taxation in jurisdictions <br /> other than North Carolina. Prospective purchasers of the 2026A Bonds should consult their own tax <br /> advisors as to the status of interest on the 2026A Bonds under the tax laws of any such jurisdiction other <br /> than North Carolina. <br /> 18 <br />