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"yield" on the Series 2024 Bonds to the Treasury of the United States. Noncompliance with <br />such provisions may result in interest on the Series 2024 Bonds being included in gross <br />income for federal income tax purposes retroactive to their date of issuance. <br />Collateral Tax Consequences <br />Except as described above, Bond Counsel will express no opinion regarding the <br />federal income tax consequences resulting from the ownership of, receipt or accrual of <br />interest on, or disposition of, the Series 2024 Bonds. Prospective purchasers of the Series <br />2024 Bonds should be aware that the ownership of the Series 2024 Bonds may result in <br />other collateral federal tax consequences. For example, ownership of the Series 2024 <br />Bonds may result in collateral tax consequences to various types of corporations relating <br />to (1) denial of interest deduction to purchase or carry such Series 2024 Bonds, (2) the <br />branch profits tax, and (3) the inclusion of interest on the Series 2024 Bonds in passive <br />income for certain Subchapter S corporations. In addition, the interest on the Series 2024 <br />Bonds may be included in gross income by recipients of certain Social Security and <br />Railroad Retirement benefits. <br />PURCHASE, OWNERSHIP, SALE OR DISPOSITION OF THE SERIES 2024 <br />BONDS AND THE RECEIPT OR ACCRUAL OF THE INTEREST THEREON MAY <br />HAVE ADVERSE FEDERAL TAX CONSEQUENCES FOR CERTAIN INDIVIDUAL <br />AND CORPORATE BONDHOLDERS, INCLUDING, BUT NOT LIMITED TO, THE <br />CONSEQUENCES DESCRIBED ABOVE. PROSPECTIVE SERIES 2024 <br />BONDHOLDERS SHOULD CONSULT WITH THEIR TAX SPECIALISTS FOR <br />INFORMATION IN THAT REGARD. <br />Other Tax Matters <br />Interest on the Series 2024 Bonds may be subject to state or local income taxation <br />under applicable state or local laws in other jurisdictions. Purchasers of the Series 2024 <br />Bonds should consult their own tax advisors as to the income tax status of interest on the <br />Series 2024 Bonds in their particular state or local jurisdictions. <br />The Inflation Reduction Act, H.R. 5376 (the IRA), was passed by both houses of <br />the U.S. Congress and was signed by the President on August 16, 2022. As enacted, the <br />IRA includes a 15 percent alternative minimum tax to be imposed on the "adjusted financial <br />statement income," as defined in the IRA, of certain corporations for tax years beginning <br />after December 31, 2022. Interest on the Series 2024 Bonds will be included in the <br />"adjusted financial statement income" of such corporations for purposes of computing the <br />corporate alternative minimum tax. Prospective purchasers that could be subject to this <br />minimum tax should consult with their own tax advisors regarding the potential tax <br />consequences of owning the Series 2024 Bonds. <br />51 <br />158 <br />