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TAX EXEMPTION The Internal Revenue Code of 1986, as amended (the "Code") establishes certain requirements which must be met subsequent to the issuance and delivery of the Series 1996 Bonds in order that interest on the Series 1996 Bonds be and remain excluded from gross income for purposes of federal income taxation. Non-compliance may cause interest on the Series 1996 Bonds to be included in Federal gross income retroactive to the date of issuance of the Series 1996 Bonds, regardless of the date on which such non-compliance occurs or is ascertained. These requirements include, but are not limited to, provisions which prescribe yield and other limits within which the proceeds of the Series 1996 Bonds and the other amounts are to be invested and require that certain investment earnings on the foregoing must be rebated on a periodic basis to the Treasury Department of the United States. The County has covenanted in the Resolution to comply with such requirements in order to maintain the exclusion from Federal gross income of the interest on the Series 1196 Bonds. In the opinion of Bond Counsel, assuming compliance with the aforementioned covenants, under existing laws, regulations, judicial decisions and rulings, interest on the Series 1996 Bonds is excluded from gross income for purposes of Federal income taxation. Interest on the Series 1996 Bonds is not an item of tax preference for purposes of the Federal alternative minimum tax imposed on individuals or corporations; however, interest on the Series 1996 Bonds may be subject to the alternative minimum tax when any Series 1996 Bond is held by a corporation. The alternative minimum taxable income of a corporation must be increased by 75% of the excess of such corporation's adjusted current earnings over its alternative minimum taxable income (before this adjustment and the alternative tax net operating loss deduction). "Adjusted Current Earning" will include interest on the Series 1996 Bonds, The Series 1996 Bonds and the income therefrom are exempt from taxation under the laws of the State of Florida except as to estate taxes and taxes imposed by Chapter 220, Florida Statutes, as amended, on interest, income or profits on debt obligations owned by corporations, banks and savings associations. 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 Series 1996 Bonds. Prospective purchasers of Bonds should be aware that the ownership of Series 1996 Bonds may result in collateral Federal income tax consequences, including (i) the denial of a deduction for interest on indebtedness incurred or continued to purchase or carry Series 1996 Bonds, (ii) the reduction of the loss reserve deduction for property and casualty insurance companies by 15% of certain items, including interest on the Series 1996 Bonds, (w) for taxable years beginning before January 1, 1996, the inclusion of interest on Series 1996 Bonds in 'modified alternative minimum taxable income" for purposes of the environmental tax imposed on corpora- tions, (iv) the inclusion of interest on the Series 1996 Bonds in earning of certain foreign corporations doing business in the United States for purposes of a branch profits tax, (v) the inclusion of interest on Series 1996 Bonds in passive income subject to Federal income taxation of certain Subchapter S corporations with Subchapter C earnings and profits at the close of the taxable year, and (vi) the inclusion of interest on the Series 1996 Bonds in "modified adjusted gross income" by recipients of certain Social Security and Railroad Retirement benefits for purposes of determining whether such benefits are included in gross income for Federal income tax purposes. PURCHASE, OWNERSHIP, SALE OR DISPOSITION OF THE SERIES 1996 BONDS AND THE RECEIPT OR ACCRUAL OF THE INTEREST THEREON MAY HAVE ADVERSE FEDERAL TAX CONSEOUENCES FOR CERTAIN INDIVIDUAL AND CORPORATE BONDHOLDERS. PROSPECTIVE BONDHOLDERS SHOULD CONSULT WITH THEIR TAX SPECIALISTS FOR INFORMATION IN THAT REGARD. During recent years legislative proposals have been introduced in Congress, and in some cases enacted, that altered attain Federal tax consequences resulting from the ownership of obligations that are similar to the Series 1996 Bonds. In some cases these proposals have contained provisions that altered these consequences on a retroactive basis. Such alteration of Federal tax consequences may have affected the market value of obligations similar to the Series 1996 Bonds. From time to time, legislative proposals are pending which could 26