Orange County NC Website
92 <br /> ORIGINAL ISSUE PREMIUM <br /> The 2026A Bonds maturing on April 1, (collectively,the"Premium Bonds")are being sold <br /> at initial offering prices 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 the 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 the Premium Bond is reduced from the owner's cost basis of the Premium <br /> Bond in determining, for federal income tax purposes, the gain or loss upon the sale, redemption or other <br /> disposition of that 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, including any issues related to any state or local taxes. Owners of <br /> Premium Bonds should consult their tax advisors with respect to the tax consequences of owning or <br /> disposing of a Premium Bond. <br /> ORIGINAL ISSUE DISCOUNT <br /> The 2026A Bonds maturing on April 1, (collectively,the"Discount Bonds")are being sold <br /> at initial offering prices which are less than the principal amounts payable at maturity. Under the Code,the <br /> difference between(a)the principal amount payable at maturity of the Discount Bonds and(b) the initial <br /> offering prices to the public (excluding bond houses and brokers) at which a substantial amount of each <br /> maturity of the Discount Bonds is sold constitutes original issue discount treated as interest which will be <br /> excludable from the gross income of the owners of those Discount Bonds for federal income tax purposes. <br /> For an owner of a Discount Bond, the amount of original issue discount on the Discount Bond is <br /> treated as having accrued daily over the term of the Discount Bond on the basis of a constant yield <br /> compounded at the end of each accrual period and is added to the owner's cost basis of the Discount Bond <br /> in determining, for federal income tax purposes, the gain or loss upon the sale, redemption or other <br /> disposition of that Discount Bond (including its sale, redemption or payment at maturity). Amounts <br /> received on the sale, redemption or other disposition of a Discount Bond that are attributable to accrued <br /> original issue discount on the Discount Bond will be treated as interest excludible from gross income,rather <br /> than as a taxable gain,for federal income tax purposes, and will not be a specific item of tax preference for <br /> purposes of the federal alternative minimum tax imposed on corporations and individuals. However, for <br /> some owners,a portion of the original issue discount that accrues in each year may result in other collateral <br /> federal income tax consequences for certain taxpayers in the year of accrual, even though the owner may <br /> not have received any cash payments attributable to the original issue discount in that year. <br /> Bond Counsel's opinion will not address issues relating to the treatment of original issue discounts <br /> on Discount Bonds, including any issues related to any state or local taxes. Owners of Discount Bonds <br /> should consult their tax advisors with respect to the tax consequences of owning or disposing of a <br /> Discount Bond. <br /> CONTINUING DISCLOSURE OBLIGATION <br /> In accordance with the requirements of Rule 15c2-12 promulgated by the Securities and Exchange <br /> Commission under the Securities Exchange Act of 1934 ("Rule 15c2-12"), the County has undertaken in <br /> 19 <br />