12 U.S.C. § 1825: Issuance of notes, debentures, bonds, and other obligations; exemptions

All notes, debentures, bonds, or other such obligations issued by the Corporation shall be exempt, both as to principal and interest, from all taxation (except estate and inheritance taxes) now or hereafter imposed by the United States, by any Territory, dependency, or possession thereof, or by any State, county, municipality, or local taxing authority: Provided , That interest upon or any income from any such obligations and gain from the sale or other disposition of such obligations shall not have any exemption, as such, and loss from the sale or other disposition of such obligations shall not have any special treatment, as such, under the Internal Revenue Code, or laws amendatory or supplementary thereto. The Corporation, including its franchise, its capital, reserves, and surplus, and its income, shall be exempt from all taxation now or hereafter imposed by the United States, by any Territory, dependency, or possession thereof, or by any State, county, municipality, or local taxing authority, except that any real property of the Corporation shall be subject to State, Territorial, county, municipal, or local taxation to the same extent according to its value as other real property is taxed. The Corporation including its franchise, its capital, reserves, and surplus, and its income, shall be exempt from all taxation imposed by any State, county, municipality, or local taxing authority, except that any real property of the Corporation shall be subject to State, territorial, county, municipal, or local taxation to the same extent according to its value as other real property is taxed, except that, notwithstanding the failure of any person to challenge an assessment under State law of such property’s value, such value, and the tax thereon, shall be determined as of the period for which such tax is imposed. No property of the Corporation shall be subject to levy, attachment, garnishment, foreclosure, or sale without the consent of the Corporation, nor shall any involuntary lien attach to the property of the Corporation. The Corporation shall not be liable for any amounts in the nature of penalties or fines, including those arising from the failure of any person to pay any real property, personal property, probate, or recording tax or any recording or filing fees when due. The Corporation shall be exempt from all prosecution by the United States or any State, county, municipality, or local authority for any criminal offense arising under Federal, State, county, municipal, or local law, which was allegedly committed by the institution, or persons acting on behalf of the institution, prior to the appointment of the Corporation as receiver. As soon as practicable after August 9, 1989 , the Corporation shall estimate the aggregate cost to the Corporation for all outstanding obligations and guarantees of the Corporation which were issued, and all outstanding liabilities which were incurred, by the Corporation before August 9, 1989 . Before issuing an obligation or making a guarantee, the Corporation shall estimate the cost of such obligations or guarantees. reflect in its financial statements the estimates made by the Corporation under paragraphs (1) and (2) of the aggregate amount of the costs to the Corporation for outstanding obligations and other liabilities, and make such adjustments as are appropriate in the estimate of such aggregate amount not less frequently than quarterly. estimate the market value of assets held by it as a result of case resolution activities, with a reduction for expenses expected to be incurred by the Corporation in connection with the management and sale of such assets; reflect the amounts so estimated in its financial statements; and make such adjustments as are appropriate of such market value not less than quarterly. the amount of cash or the equivalent of cash held by the Deposit Insurance Fund; the amount which is equal to 90 percent of the Corporation’s estimate of the fair market value of assets held by the Deposit Insurance Fund, other than assets described in subparagraph (A); and the total of the amounts authorized to be borrowed from the Secretary of the Treasury pursuant to section 1824(a) of this title . any guarantee issued by the Corporation, other than deposit guarantees; any amount borrowed pursuant to section 1824 of this title ; and any other obligation for which the Corporation has a direct or contingent liability to pay any amount. The Corporation shall value any contingent liability at its expected cost to the Corporation. the principal amount of such obligation is stated in the obligation; and the term to maturity or the date of maturity of such obligation is stated in the obligation.