Call 855-808-4530 or email [email protected] to receive your discount on a new subscription.
Over the last year, it has become obvious that there must be a fundamental shift in the way large-ticket leasing companies look at their tax shelter businesses. This article will examine what has brought about this shift and how lessors will find ways to cope with it.
In the 70s, 80s and early 90s, the large-ticket equipment leasing business consisted mainly of investments in equipment transactions wherein lessors bought and then leased equipment to corporate lessees. This business was fairly basic wherein corporations, which for one reason or another could not use tax benefits, would sell a piece of equipment to a lessor and lease it back, in essence trading tax benefits for a lower after-tax cost of financing. As companies became profitable in the mid- to late-90s, corporate users of equipment required less of the aforementioned financings. Companies discovered that they could make more efficient use of the tax benefits themselves than by trading them through leases. This led to lessors looking for new types of transactions where they could still generate tax benefits from equipment financings, and lessors found a new market in tax-exempt entities. While the corporate transactions of the earlier era relied on the credit of the lessee directly, transactions to the tax-exempt entities generally involved some form of credit enhancement in addition to the credit of the lessee. Although the lessee was always primarily liable, credit committees of investors required support for the credit of the lessee.
There's current litigation in the ongoing Beach Boys litigation saga. A lawsuit filed in 2019 against Nevada residents Mike Love and his wife Jacquelyne in the U.S. District Court for the District of Nevada that alleges inaccurate payment by the Loves under the retainer agreement and seeks $84.5 million in damages.
This article highlights how copyright law in the United Kingdom differs from U.S. copyright law, and points out differences that may be crucial to entertainment and media businesses familiar with U.S law that are interested in operating in the United Kingdom or under UK law. The article also briefly addresses contrasts in UK and U.S. trademark law.
With each successive large-scale cyber attack, it is slowly becoming clear that ransomware attacks are targeting the critical infrastructure of the most powerful country on the planet. Understanding the strategy, and tactics of our opponents, as well as the strategy and the tactics we implement as a response are vital to victory.
The Article 8 opt-in election adds an additional layer of complexity to the already labyrinthine rules governing perfection of security interests under the UCC. A lender that is unaware of the nuances created by the opt in (may find its security interest vulnerable to being primed by another party that has taken steps to perfect in a superior manner under the circumstances.
The real property transfer tax does not apply to all leases, and understanding the tax rules of the applicable jurisdiction can allow parties to plan ahead to avoid unnecessary tax liability.