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Prospective investors should consult their own tax advisors in determining the U.S. federal, state, local or non -U.S. tax consequences to them from the purchase, ownership and disposition of the Series 2018B Bonds in light of their particular circumstances. U.S. Holders Interest. Interest on the Series 2018B Bonds generally will be taxable to a U.S. Holder as ordinary interest income at the time such amounts are accrued or received, in accordance with the U.S. Holder's method of accounting for U.S. federal income tax purposes. To the extent that the issue price of any maturity of the Series 2018B Bonds is less than the amount to be paid at maturity of such Series 2018B Bonds (excluding amounts stated to be interest and payable at least annually over the term of such Series 2018B Bonds) by more than a de minimis amount, the difference may constitute original issue discount ("OID"). U.S. Holders of Series 2018B Bonds will be required to include OID in income for U.S. federal income tax purposes as it accrues, in accordance with a constant yield method based on a compounding of interest (which may be before the receipt of cash payments attributable to such income). Under this method, U.S. Holders generally will be required to include in income increasingly greater amounts of OID in successive accrual periods. Series 2018B Bonds purchased for an amount in excess of the principal amount payable at maturity (or, in some cases, at their earlier call date) will be treated as issued at a premium. A U.S. Holder of a Series 2018B Bond issued at a premium may make an election, applicable to all debt securities purchased at a premium by such U.S. Holder, to amortize such premium, using a constant yield method over the term of such Series 2018B Bond. Sale or Other Taxable Disposition of the Series 2018B Bonds. Unless a nonrecognition provision of the Code applies, the sale, exchange, redemption, retirement (including pursuant to an offer by the Successor Agency) or other disposition of a Series 2018B Bond will be a taxable event for U.S. federal income tax purposes. In such event, in general, a U.S. Holder of a Series 2018B Bond will recognize gain or loss equal to the difference between (i) the amount of cash plus the fair market value of property received (except to the extent attributable to accrued but unpaid interest on the Series 2018B Bond, which will be taxed in the manner described above) and (ii) the U.S. Holder's adjusted U.S. federal income tax basis in the Series 2018B Bond (generally, the purchase price paid by the U.S. Holder for the Series 2018B Bond, decreased by any amortized premium, and increased by the amount of any OID previously included in income by such U.S. Holder with respect to such Series 2018E Bond). Any such gain or loss generally will be capital gain or loss. In the case of a non -corporate U.S. Holder of the Series 2018B Bonds, the maximum marginal U.S. federal income tax rate applicable to any such gain will be lower than the maximum marginal U.S. federal income tax rate applicable to ordinary income if such U.S. holder's holding period for the Series 2018B Bonds exceeds one year. The deductibility of capital losses is subject to limitations. Defeasance of the Series 2018B Bonds. If the Successor Agency defeases any Series 2018B Bond, the Series 2018B Bond may be deemed to be retired and "reissued" for U.S. federal income tax purposes as a result of the defeasance. In that event, in general, a holder will recognize taxable gain or loss equal to the difference between (i) the amount realized from the deemed sale, exchange or retirement (less any accrued qualified stated interest which will be taxable as such) and (ii) the holder's adjusted tax basis in the Series 2018B Bond. Information Reporting and Backup Withholding. Payments on the Series 2018B Bonds generally will be subject to U.S. information reporting and possibly to "backup withholding." Under Section 3406 of the Code and applicable U.S. Treasury Regulations issued thereunder, a non -corporate U.S. Holder of the Series 2018B Bonds may be subject to backup withholding at the current rate of 24% with respect to "reportable payments," which include interest paid on the Series 2018B Bonds and the gross proceeds of a sale, exchange, redemption, retirement or other disposition of the Series 2018B Bonds. The payor will be required to deduct and withhold the prescribed amounts if (i) the payee fails to furnish a U.S. taxpayer identification number ("TIN") to the 51 SA -3-65