2024-023 - Laserfiche WebLink

Home Browse Search

"yield" on the Series 2024 Bonds to the Treasury of the United States. Noncompliance with such provisions may result in interest on the Series 2024 Bonds being included in gross income for federal income tax purposes retroactive to their date of issuance. Collateral Tax Consequences Except as described above, Bond Counsel will express. no opinion regarding the federal income tax consequences resulting from the ownership of, receipt or accrual of interest on, or disposition of, the Series 2024 Bonds. Prospective purchasers of the Series 2024 Bonds should be aware that the ownership of the Series 2024 Bonds may result in other collateral federal tax consequences. For. example, ownership of the Series 2024 Bonds may result in collateral tax consequences to various types. of corporations relating to (1) denial of interest deduction to purchase or carry such Series 2024 Bonds, (2) the . branch profits tax, and (3) the inclusion of interest on the Series 2.024 Bonds in passive income for certain Subchapter S corporations. In addition, the interest'on the Series 2024 Bonds may be included in gross income by recipients , of certain Social Security and Railroad Retirement benefits. PURCHASE, OWNERSHIP, SALE OR DISPOSITION OF 'THE SERIES 2024 BONDS AND THE RECEIPT OR ACCRUAL. OF THE INTEREST THEREON MAY, HAVE ADVERSE FEDERAL TAX CONSEQUENCES FOR CERTAIN INDIVIDUAL AND CORPORATE BONDHOLDERS, INCLUDING, BUT NOT LIMITED TO, THE CONSEQUENCES DESCRIBED ABOVE.. PROSPECTIVE SERIES 2024 BONDHOLDERS SHOULD CONSULT WITH THEIR TAXSPECIALISTS FOR INFORMATION IN THAT REGARD. Other Tax Matters Interest on the Series' 2024 Bonds may be subject to state or local income taxation under applicable state or local laws in other jurisdictions.. Purchasers of the Series 2024 Bonds should consult their own tax advisors as to the income tax status 'of interest on the Series 2024 Bonds in their particular state or local jurisdictions. The Inflation Reduction Act, H.R.. 5376 the ERA), was passed both houses of ( ) p �' the U.S. Congress and was signed by the President on August 16,, 2022. -As enacted, the IRA includes a 15 percent alternative minimum tax to be imposed on the "adjusted financial statement income," as defined in the IRA, of certain corporations for: tax. years beginning after December 31, 2022. Interest on the Series 2024 Bonds will be included in. the "adjusted financial statement income of such corporations for purposes. of computing the corporate alternative minimum tax. Prospective purchasers that could be subject to this minimum tax should consult with their own tax advisors regarding the potential tax consequences of owning the Series 2024 Bonds. 51