Bob McDonnell to the Virginia College Building Authority, which provides financing for capital projects and educational equipment for state higher education institutions and a conduit financing
mechanism for private, nonprofit higher education institutions.
The five-year conduit financing
was provided by Natixis Real Estate Capital LLC and features interest-only payments for the full term.
Similarly, under the conduit financing
regulations, the IRS has the authority to disregard, for purposes of [section] 881, the participation of one or more intermediate entities in a "financing arrangement" where the entities are acting as conduit entities.
McNair, (34) the Supreme Court held that a revenue bond issuance benefiting a sectarian institution did not violate the Establishment Clause, (35) but noted that conduit financing
would have the effect of advancing religion when used to fund a loan for a pervasively sectarian institution.
To apply, companies contact a financial adviser who helps them put together the necessary paperwork and guides them through a roughly 90-day process that, if successful, leads toward what is known as conduit financing
The taxable years at issue in the TAMs were 1990-1994, which precede the final conduit financing
regulations issued pursuant to Sec.
On October 11, 1994, the IRS issued the first part of proposed regulations on conduit financing
arrangements under IRC section 7701(l).
The final key provision for multi-nationals authorizes regulations to be issued to attack conduit financing
arrangements where a U.
An illustration of the ability of a high-volume mortgage intermediary like Meridian to deliver conduit financing
for relatively small loans is our deal on 239 Knickerbocker Avenue in Brooklyn.
borrower involved in a "financing arrangement" that is a conduit financing
arrangement when the ultimate U.
7701(l) is the statutory basis for the conduit financing
Once an IE is determined to be a conduit (called a "conduit entity" in the regulations), the IRS then has discretion to determine whether the conduit's participation in a conduit financing
arrangement "should be disregarded for purposes of section 881.