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Other provisions of the Internal Revenue Code of 1986 affect the purchasers and holders of certain state and local government obligations. Among these provisions is a provision that interest on certain categories of state and local government obligations may be treated as a tax preference item in the computation of individual and corporate minimum taxes; a provision for a corporate minimum tax computed in part on the basis of a pre-tax book income or earnings and profits, which may include interest on state and local government obligations; an increase in the disallowance of interest deduction for financial institutions' costs of carrying tax-exempt obligations; a requirement that certain categories of insurance companies reduce their loss reserve deduction by a percentage of their tax-exempt income; and a requirement that for tax returns filed after 1987 that all taxpayers must report their tax-exempt income. The Superfund Revenue Act of 1986 On October 22, 1986, the President of the United States signed into law the Superfund Amendments and Reauthorization Act of 1986, Title V of which is the "Superfund Revenue Act of 1986", an amendment to the Internal Revenue Code of 1986. Various taxes are levied under such Act to fund the environmental Superfund over the next five years, among which is a tax on corporations based upon modified alternative minimum taxable income, which may include interest on state and local government obligations held by the corporation. See "TAX EXEMPTION --Environmental Tax on Corporations" herein for a further discussion. In General In issuing the Notes, reliance has been placed upon the text of the Internal Revenue Code of 1986 as it was signed by the President on October 22, 1986, and the Superfund Revenue Act of 1986, as it was signed on October 22, 1986. No representation is made or can be made by the County or any other party associated with the issuance of the Notes as to whether or not any other legislation now or hereafter introduced and enacted will be applied retroactively so as to subject interest on the Notes to federal income taxes or so as to otherwise affect the marketability or market value of the Notes. Enactment of any legislation that retroactively imposes taxation on the interest on the Notes could adversely affect the market value and marketability of the Notes. 28