- 10 - out and (2) the rental payments that the beneficiary deducted were fully offset by the payments due the beneficiary under the equipment purchase installment note. The ultimate beneficiary/ customer’s potential net tax benefits in the first lease strip deal equaled the total rental payments due under the wraparound lease less the interest portion of the installment note payments. According to a tax opinion issued to CFX Corp. (CFX) (the first lease strip deal’s ultimate beneficiary/ customer), while the economic cost of the deal to CFX would be approximately $2.9 million, the deal would generate approximately $13.8 million in potential net tax deductions for CFX over the life of the wraparound lease. In each of the two lease strip deals, the ultimate beneficiary/customer’s only prospect of realizing a pretax economic profit on the deal essentially depended upon whether the rental income produced during the wraparound lease residual periods would exceed the economic investment in the deal. In addition, although a series of complex multiparty transactions (which are discussed in more detail infra) was required to implement each of these two lease strip deals, typically, the beneficiary/customer infused the only noncircuitous cash paid to participants, brokers, lawyers, and others involved in setting up that deal.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011