Assignments by the financing entity of the financed entity's loan to an intermediate entity (see Aiken Industries).
For example, if a financing entity capitalizes an intermediate entity only through an ordinary common stock investment and the intermediate entity lends the funds to the financed entity, there will not be a financing arrangement.
he IRS has previously applied conduit principles to disregard an intermediate entity apparently in an ordinary preferred stock situation; see Letter Ruling (TAM) 9133004 (stock investment in intermediate entity, followed by loan to the financed entity, its U.
Whether the intermediate entity would have been able to make the advance to the financed entity without the advance to it from the financing entity; 3.
A single periodic invoice includes all leased and financed
resources, which allows clients to benefit from simplified budgeting, planning, and accounts payable, thus enhancing the total value of transactions.