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that the ownership of Bonds may result in collateral federal income tax consequences, <br />including (i) the denial of a deduction for interest on indebtedness incurred or <br />continued to purchase or carry Bonds, (ii) the reduction of the loss reserve deduction <br />for property and casualty insurance companies by 15% of certain items, including <br />interest on the Bonds, (iii) the inclusion of intereston the Bonds in earnings of certain <br />foreign corporations doing businessin the United States for purposes of a branch <br />profits tax, (iv) the inclusion of interest on Bonds in passive income subject to federal <br />income taxation of certain S corporations with Subchapter C earnings and profits at <br />the close of the taxable year, and (v) the inclusion of interest on the Bonds in "modified <br />adjusted gross income" by recipients of certain Social Security and Railroad Retirement <br />benefits for purposes of determining whether such benefits are included in gross <br />income for federal income tax purposes. <br />PURCHASE, OWNERSHIP, SALE OR DISPOSITION OF THE BONDS AND <br />THE RECEIPT OR ACCRUAL. OF THE INTEREST THEREON MAY HAVE <br />ADVERSE FEDERAL TAX CONSEQUENCES FOR CERTAIN INDIVIDUAL AND <br />CORPORATE REGISTERED OWNERS. PROSPECTIVE REGISTERED OWNERS <br />SHOULD CONSULT WITH THEIR TAX SPECIALISTS FOR INFORMATION IN <br />THAT REGARD. <br />During recent years legislative proposals have been introduced in Congress, and <br />in some cases enacted that altered certain federal tax consequences resulting from the <br />ownership of obligations that are similar to the Bonds. In some cases these proposals <br />have contained provisions that altered these consequences on a retroactive basis. Such <br />alteration of federal tax consequences may have affected the market value of <br />obligations similar to the Bonds. From time to time, legislative proposals are pending <br />which could have an effect on both the federal tax consequences resulting from <br />ownership of Bonds and their market value. No assurance can be given that legislative <br />proposals will not be introduced or enacted that would or might apply to, or have an <br />adverse effect upon, the Bonds. <br />Tax Treatment of Original Issue Discount <br />Under the Code, the difference between the maturity amount of the Discount <br />Bonds maturing in the years through , inclusive, (the "Discount Bonds") and <br />the initial offering price to the public, excluding bond houses, brokers or similar <br />persons or organizations acting in the capacity of underwriters or wholesalers, at <br />which price a substantial amount of Discount Bonds of the same maturity was sold is <br />"original issue discount." Original issue discount will accrue over the term of such <br />29 <br />