As noted by the court, "[i]t remains exceedingly difficult to make money merely by buying things" Accordingly, it held that cash advances in exchange for volume purchase commitments, subject to pro-rata
repayment if such commitments are not met, are not income when received.
Thus, it reasoned the S corporation owned a direct, pro-rata
interest in the LIFO inventory on the books of each newly created partnership, requiring the corporation to recapture its pro-rata
share of the partnerships' LIFO inventory reserves into income.
pay structures have become more common among all cash flow CDO market sectors.
Many middle market CLOs of late have been utilizing a pro-rata
pay structure where all the notes in the capital structure receive principal amortization based on their percentage of the entire structure prior to any rating triggers,' said Alla Zaydman, Director, Fitch Ratings.
middle market collateralized loan obligations throughout the remainder of 2005, fewer upgrades may take place if pro-rata
pay structures and revolving collateral pools continue to become more prevalent once deals start to significantly amortize, according to an updated criteria report by the agency.
The $134 million (projected cost at the Company's full and pro-rata
share) open-air regional lifestyle center will feature anchor stores Macy's and Robinsons-May and currently has approximately 60 signed leases.
The Sniper shares would be distributed to all USR shareholders of record as a dividend on a pro-rata
E[acute accent](d) In the event that the Optionee making the final (additional) cash payment to Becker of $120,000, then it will acquire an additional 5% interest (resulting in an aggregate 80% interest), at which time a joint venture will be formed, whereby each of the Optionee and Becker will be responsible for the exploration and production costs in respect of the development of the Property on a pro-rata
basis (the Optionee as to 80% and Becker as to 20%).