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he includible in gross income for calculation of reguLar income tax liability. 't'hn trotes are not 1' specified private Activity bonds" Within the meaning of Section 57(x)(5) of the IritntnaL Revenue COdn Of VJF16 and, thernf.nrn, internist on the Notes will not be treated As a preference lte for purposes of c'n'.1p,st-in-1 the alternative miriimiim tax imposed on in:livid-ALa by _Section 5" of the Internal Nev,,nue Code of 1956. F'rnspec:t-ive cr,rporate purchasers of th� Notes r1t +rid connult their piofe!sslone I tax advisors as to t.hn p.otnntiaL Impact that Ownership of the Notes could have upon their cnr-porate in':Csme tAx liability. Foreicfn ('orporat.ion Rranch Profits Tax Under the rWeg nal Revenue Code of 1986, a^ amenief. A "branch profits t -arc" to imposed on the earnings an -I pt -tit,. It the 'Init.ed State." btanchee of foreign corporations. The Conr-rence Committee Report accompanying the Tax Refotn A -:t_ of 1141h I114licatee that it was the Congressional intent to irr-:Lsiie interest earned on tax-exempt state and local government oisli�:fatA ones in the calculation of the earnings and profit.n that. w,)WA 1— rublert, to the branch profits tax. F-wre19n corporations conOldet ing t.trn purchase of the Not-, should consult their professionaL tax ,,ivisora as to the effw<:t Interest. inr,ome from the Notes may (liv— upon their liability for toxen In the United Staten. 6nvironmont.at Tax on Corporations Under the Superfurs-i Rovewle A, --t of 1486, which amends the Internal Rev*nue Code of 1996, a new "environmental tax' genet'aLly bAned can corporate alternative minimum taxable income is imposed. The tax in 0.1 percent of the excess C>f alEernative minimum taxable inc mn, withouE regard to net operating losse_a and the deductian for this tax, over $.,000,000. The "environmental tax" will be imposed Whether or not the taxpayer is subject to the alternative minimum tax, but Ruch tax is deductible from gross income. The tax is effective for taxable years beginning after December 31, 11?86. As noted above, under the heading "Federal Alternative Minimum Tax Calculations," alternative minimum taxable income of a corporation may include interest on state and local government obligations held by the corporation. Prospective corporate purchasers of the Notes may Wish to consult their professional tax advisors as to the impact of 30