“It's like corporate cocaine. They just can't get enough"
- A party that could not use the Credit (Seller) was matched with a party that could (Buyer)
- The Seller sold assets generating the Credit to the Buyer
- The Buyer paid for the assets with the revenue generated by such assets, but maintained enough of an economic interest in the property to justify being an owner entitled to take the Credit.
- Andersen would seek a Letter Ruling (LTR) from the Internal Revenue Service (IRS) to confirm the tax treatment of the transaction to ensure the parties received the tax treatment they sought given the creative and risky nature of the Vehicle structure.
Robert and I were waiting at an airport gate for a trip to Washington D.C. to discuss a nuance of one of the Vehicle transactions with the IRS National Office. Such was Robert's command and expertise of the subject matter that the IRS asked his guidance as to how to draft the LTR language on a particularly complex Vehicle.