CMA Consolidated, Inc. & Subsidiaries, Inc. - Page 10

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          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.                                                                  








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