In denying the taxpayer's claims, the court in Continental Vending first noted that Fahs was distinguishable because the debt was a secured obligation
Thus, a transfer of a secured obligation
by the seller of the property to a controlled corporation and a subsequent repossession of real property by the corporation would avoid Sec.
The portfolio will comprise a minimum of 90% senior secured obligations
Finally, the notes will be guaranteed by CEMEX MAaAaAeA@xico SA de CV, CEM Concretos SA de CV, Empresas Tolteca de MAaAaAeA@xico SA de CV, New Sunwa Holding BV, CEMEX EspaAaAaAeA~a SA, Cemex Asia BV, CEMEX Finance LLC, CEM Corp, Cemex Egyptian Investments BV, CEMEX France Gestion (SAS), Cemex Research Group AG and CEMEX UK, which will all share in the collateral pledged for the benefit of the lenders under the 2017 Credit Agreement and other secured obligations
having the benefit of such collateral.
The Notes are senior secured obligations
Air Canada's obligations under the credit facility are senior secured obligations
of Air Canada, secured on a first lien basis, subject to certain permitted liens and exclusions, by certain real estate interests, ground service equipment, certain airport slots and gate leaseholds, and certain Pacific routes and the airport slots and gate leaseholds utilized in connection with these Pacific routes.
According to the company, the senior unsecured notes will be its general unsecured senior obligations, will be subordinated to all of its existing and future senior secured obligations
to the extent of the value of the collateral securing its senior secured obligations
and will be structurally subordinated to all obligations and liabilities of its subsidiaries.
Fitch understands that JAFZ has confirmed that its obligations under its undertaking to purchase will be its direct, unconditional and secured obligations
and will at all times rank pari passu with its other unsubordinated and secured obligations
from time to time outstanding.
The notes will be the senior secured obligations
of ILFC and will be guaranteed on a senior secured basis by certain of ILFCas wholly owned subsidiaries.
The senior secured notes will be senior secured obligations
of the airline.
The first lien notes will be senior secured obligations
of United, with the company's obligations under these notes guaranteed on a senior unsecured basis by UAL and certain of UAL's subsidiaries.
1996) (attorneys' fees paid out under a structured settlement were not funded or secured obligations
, but mere promises to pay and, thus, only taxable in the year of actual receipt).