John was in private practice in Des Moines for 20 years prior to his move to De Lage Landen representing commercial banks and other lenders in asset based lending, securitizations, secured and unsecured commercial lending and consumer finance transactions involving various structures and serving as bond counsel and underwriter, issuer, and borrower counsel in traditional government financing and conduit financing
The five-year conduit financing
was provided by Natixis Real Estate Capital LLC and features interest-only payments for the full term.
Under the regulations, the "conduit company" is defined as "an intermediate entity whose participation in a financing arrangement may be disregarded in whole or in part" (87) and a "conduit financing
arrangement" is defined as a financing arrangement effectuated through one or more conduit entities.
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.
: Bonds are issued by a nonprofit entity and the city makes lease payments to the nonprofit, which uses the money to service the debt.
The court held that the nature of the institution is irrelevant and that the conduit financing
advanced a governmental interest without creating the impression that the government was endorsing religion.
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.
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.S.
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.