Product Details

International Leasing: A Dynamic Industry Under Constraint
By Lawrence M. Taylor, Jr., Esq.
Summer 1984

After providing a brief history of the development of the equipment leasing industry outside the U.S. and an analysis of the position of U.S. multinational leasing firms in that market, the author examines constraints upon the growth of the industry and recommends government action that will facilitate industry expansion and the accompanying increased export of U.S. goods and financial services.

The 90-Day ITC Window:
Tailoring the Emperor\'s New Clause
By Barry S. Marks, Esq.
Summer 1984

The Tax Equity and Fiscal Responsibility Act of 1982 amended section 48(b) of the Internal Revenue Code to postpone the "originally placed in service" date for Investment Tax Credit (ITC) purposes for up to three months. The language seems to permit sale-leasebacks and other lease structures to vest ITC for new section 38 property in the lessor, even after equipment is used by the lessee. In this article, the author examines the pitfalls and benefits of various structures utilizing this 90-day window, with particular emphasis on multiple-item transactions and the role of the leasing company. An addendum to the article is included based upon the revisions made in the 1984 tax bill.

Toward a New Understanding of Leveraged Lease Profitability
By Edward P. Brennan
Summer 1984

Existing leveraged lease analytical methods and structuring techniques are premised upon the concept that a leveraged lease is a "unitary" opportunity. This concept, in the author\'s opinion, has resulted in a twenty-year history of confusion in measuring the profitability of a leveraged lease. The article reviews the history, development and inadequacy of the existing major analytical methods and structuring techniques, and proposes a new, simple and "foolproof" approach, the Binary Lease Profitability Index, for evaluating the profitability of a leveraged lease. The new approach is based upon perceiving the leveraged lease as presenting the investor with two distinct opportunities (hence, binary), an investment opportunity and a financing opportunity, which need to be evaluated separately.

Wrap Leases: Structural and Tax Considerations
By Allen P. Palles, Esq.
Summer 1984

The article discusses the fundamental economic, structural and tax aspects of the wrap lease, identifying it as a structural variation of the leveraged lease.

International Leasing: A Dynamic Industry Under Constraint<br />By Lawrence M. Taylor, Jr., Esq.<br />Summer 1984<br /><br />After providing a brief history of the development of the equipment leasing industry outside the U.S. and an analysis of the posit