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in said certificate, the Series 1993 Bonds are not presently "arbitrage bonds" under existing statutes, regulations and judicial decisions. No representation is made or can be made by the County or any other party associated with the issuance of the Series 1993 Bonds as to whether or not any legislation now or hereafter introduced and enacted will be applied retroactively so as to subject interest on the Series 1993 Bonds to inclusion in gross income for Federal income tax purposes or so as to otherwise affect the marketability or market value of the Series 1993 Bonds. Enactment of any legislation that subjects the interest on the Series 1993 Bonds to inclusion in gross income for federal income tax purposes or otherwise imposes taxation on the Series 1993 Bonds or the interest paid thereon may have an adverse effect on the market value or marketability of the Series 1993 Bonds. Florida Tax Matters On the date of delivery of the Series 1993 Bonds, Bond Counsel will issue an opinion to the effect that under existing statutes, regulations and judicial decisions, the Series 1993 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 savings associations. Other Federal Income Tax Matters Interest Expense Deductions for Financial Institutions Under the Code, financial institutions are disallowed 100 percent of their interest expense deductions that are allocable, by a formula, to tax-exempt obligations acquired after August 7, 1986. An exception, which reduces the amount of the disallowance, is provided for tax-exempt obligations issued by a qualified issuer that specifically designates such obligations as "qualified tax-exempt obligations" under Section 265 of the Code. The Series 1993 Bonds have not been designated as "qualified tax-exempt obligations." Financial institutions intending to purchase Series 1993 Bonds should consult with their professional tax advisors to determine the effect of the interest expense disallowance on their federal income tax liability. Original Issue Discount In the opinion of Bond Counsel, under existing statutes, regulations and judicial decisions, the original issue discount in the selling price of those maturities of the Series 1993 Bonds being sold in the initial public offering with original issue discount is, to the extent properly allocable to each Holder of such Series 1993 Bonds, excludable from gross income for federal income tax purposes of such Holder, but may not be excludable from the calculation of "adjusted current earnings" for purposes of the alternative minimum tax imposed on corporations (as defined for federal income tax purposes). The original issue discount with respect to any maturity of the Series 1993 Bonds is the excess of the stated redemption price at maturity of such Series 1993 Bonds over the initial offering price at which a substantial amount of the Series 1993 Bonds of such maturity were sold to the public, excluding underwriters and other intermediaries, in the initial public offering. Accrued original issue discount will increase a Holder's tax basis in a Series 1993 Bond and affect the determination of taxable gain from any We or exchange of such Series 1993 Bond. Prospective purchasers of the Series 1993 Bonds being sold in the initial public offering with original issue discount should consult their tax advisors for further information concerning the manner in which the original issue discount is apportioned among successive holders and the tax consequences of purchasing, holding and selling such bonds.