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06/04/2024
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06/04/2024
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Last modified
8/5/2024 1:34:55 PM
Creation date
8/5/2024 12:58:41 PM
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Meetings
Meeting Type
BCC Regular Meeting
Document Type
Agenda Packet
Meeting Date
06/04/2024
Meeting Body
Board of County Commissioners
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During prior years, legislative proposals have been introduced in Congress, and in <br />some cases enacted, that altered certain federal tax consequences resulting from the <br />ownership of obligations that are similar to the Series 2024 Bonds. In some cases, these <br />proposals have contained provisions that altered these consequences on a retroactive basis. <br />Such alteration of federal tax consequences may have affected the market value of <br />obligations similar to the Series 2024 Bonds. From time to time, legislative proposals are <br />pending which could have an effect on both the federal tax consequences resulting from <br />ownership of the Series 2024 Bonds and their market value. No assurance can be given that <br />additional legislative proposals will not be introduced or enacted that would or might apply <br />to, or have an adverse effect upon, the Series 2024 Bonds. <br />Tax Treatment of Original Issue Discount <br />Certain of the Series 2024 Bonds (the "Discount Bonds") may be offered and sold <br />to the public at an original issue discount, which is the excess of the principal amount of <br />the Discount Bonds over the initial offering price to the public, excluding bond houses, <br />brokers or similar persons or organizations acting in the capacity of underwriters or <br />wholesalers, at which initial offering price a substantial amount of the Discount Bonds of <br />the same maturity was sold. Original issue discount represents interest which is excluded <br />from gross income for federal income tax purposes to the same extent as interest on the <br />Discount Bonds. Original issue discount will accrue over the term of a Discount Bond at <br />a constant interest rate compounded semi-annually. An initial purchaser who acquires a <br />Discount Bond at the initial offering price thereof to the public will be treated as receiving <br />an amount of interest excludable from gross income for federal income tax purposes equal <br />to the original issue discount accruing during the period such purchaser holds such <br />Discount Bonds and will increase the adjusted basis in such Discount Bonds by the amount <br />of such accruing discount for purposes of determining taxable gain or loss on the sale or <br />other disposition of such Discount Bonds. The federal income tax consequences of the <br />purchase, ownership and prepayment, sale or other disposition of Discount Bonds which <br />are not purchased in the initial offering at the initial offering price may be determined <br />according to rules which differ from those above. Owners of Discount Bonds should <br />consult their own tax advisors with respect to the precise determination for federal income <br />tax purposes of interest accrued upon sale, prepayment or other disposition of such <br />Discount Bonds and with respect to the state and local tax consequences of owning and <br />disposing of such Discount Bonds. <br />Tax Treatment of Bond Premium <br />Certain of the Series 2024 Bonds (the "Premium Bonds") may be offered and sold <br />to the public at an initial offering price in excess of the principal amount of such Premium <br />Bond, which excess constitutes to an initial purchaser amortizable bond premium which is <br />not deductible from gross income for Federal income tax purposes. The amount of <br />amortizable bond premium for a taxable year is determined actuarially on a constant <br />interest rate basis over the term of the Premium Bonds which term ends on the earlier of <br />52 <br />159 <br />
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