Laserfiche WebLink
imposed by Chapter 220, Florida Statutes, on interest, income or profits on debt <br />obligations owned by corporations, banks and savings associations. <br />6. Assuming investment and application of the proceeds of the Series <br />1993 Bonds as set forth in the Resolution and the aforementioned non-arbitrage <br />certificate, The Series 1993 Bonds are not presently "arbitrage bonds" as <br />described in Section 103(b)(2) and Section 148 of the Code and applicable <br />regulations promulgated thereunder. <br />7. Interest on the Series 1993 Bonds (including any original issue <br />discount properly allocable to the holder thereof) is excluded from gross income <br />for purposes of federal income taxation and is not an item of tax preference for <br />purposes of the federal alternative minimum tax imposed on individuals and <br />corporations under present statutes, regulations and judicial decisions; although <br />it should be noted that in the case of corporations (as defined for federal <br />income tax purposes), such interest is taken into account in determining adjusted <br />current earnings for purposes of such alternative minimum tax. The opinions <br />expressed in this paragraph are subject to the condition that the County comply <br />with all requirements of the Code that must be satisfied subsequent to the <br />issuance of the Series 1993 Bonds in order that the interest thereon be, or <br />continue to be, excluded from gross income for federal income tax purposes, as <br />the County has covenanted to do in the Resolution and other aforementioned <br />documents. Failure to comply with certain of such requirements may cause the <br />inclusion of interest on the Series 1993 Bonds in gross income retroactive to the <br />date of issuance of the Series 1993 Bonds. <br />We express no opinion regarding other federal tax consequences arising with <br />respect to the Bonds. <br />It is to be understood that the rights of the holders of the Series 1993 <br />4 <br />