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earnings for purposes of such alternative minimum tax. Bond Counsel expresses no other opinion with regard to federal income tax consequences arising with respect to the Series 1991 Bonds. The Series 1991 Bonds and the income therefrom are exempt from taxation under the laws of the State of Florida, except as to estate taxes and taxes imposed by Chapter 220, Florida Statutes, on interest, income or profits on debt obligations owned by corporations, banks, and saving associations. Non -Arbitrage Bonds The County will issue its certificate to the effect that on the basis of the facts, estimates and circumstances in existence on the date of delivery of the Series 1991 Bonds, it is not expected that proceeds of the Series 1991 Bonds will be used in a manner that would cause the Series 1991 Bonds to be "arbitrage bonds". Such certificate will be accompanied by an opinion of Bond Counsel, based upon the facts, estimates and circumstances set forth in said certificate, that the Series 1991 Bonds are not currently "arbitrage bonds," under existing statutes, regulations and decisions. The County has also covenanted in the Resolution with the purchasers of the Series 1991 Bonds that it will make no use of the proceeds of the Series 1991 Bonds which will cause the Series 1991 Bonds to become "arbitrage bonds," and has further covenanted in the Resolution to comply with the requirements of Section 103 and 148 of the Internal Revenue Code of 1986, as amended, and regulations promulgated thereunder from time to time, during the term of the Series 1991 Bonds, if and to the extent applicable to maintain continuously the exclusion of interest on the Series 1991 Bonds from gross income for Federal income tax purposes. Corporate Alternative Minimum Taxes; Environmental Tax; Branch Profits Tax Interest on the Series 1991 Bonds may be includable in a corporation's "adjusted net book income" upon which alternative minimum taxable income is calculated and such interest may also be included in corporate alternative minimum taxable income that is subject to the environmental tax imposed under Section 59A of the Internal Revenue Code of 1986, as amended (the "Code"). In addition, such interest may be includable in the amount upon which certain foreign corporations are required to pay the branch profits tax imposed under Section 884 of the Code. Prospective 28