So, even if PIPEs carry the stigma that they are financings
of last resort, that is just fine with company executives like Christopher Wood, the 58-year-old surgeon who is chairman and CEO of Bioenvision Inc., a New York-based biopharmaceutical company.
companies or who need to refinance owe it to themselves - and their businesses - to have a sound understanding of this financing
Because there can be no financing
arrangement unless the parties are connected by a chain of financing
transactions, the IRS was concerned that two related parties could transfer funds through means other than a financing
transaction, thus breaking the chain and defeating the purpose of the regulations.
However, in a subsequent case, Coulter Electronics, Inc., TC Memo 1990-186, the Tax Court ruled that whether revenues from a transaction are income from a sale of the property or income from a secured financing
is not a question of the proper time for the inclusion of an item of income.
Fulbright's work on the Mets stadium is just the latest in a long string of major stadium and arena financings
that the firm has worked on.
The new provision consists of a single sentence that authorizes the Department of the Treasury to issue regulations "recharacterizing any multiple-party financing
transaction as a transaction directly among any two or more of such parties" where the Internal Revenue Service determines that this is necessary to prevent tax avoidance.
Frank Bissaillon, of La Quinta Motor Inns, discusses his firm's financing
below.) But, even for credits of Fleming's ilk, the public debt market has in recent months become more name-selective and story-sensitive.
activity in May remained solid, with many properties still borrowing to fund a wide range of capital improvement projects or refinance existing debt," stated Howe.
SBO arranged the construction leasehold financing
for the 188 Ludlow Street project, including financing
provided by low-floater tax-exempt bonds issued by the New York State Housing Finance Agency ("HFA") under its 80/20 Program, together with credit enhancement in the form of an $83 million Letter of Credit for the HFA bonds provided by Helaba, a commercial bank.
While there is still plenty of capital available for top-quality projects, even the best developers will have difficulty securing financing
for more marginal projects over the next few years.
"The NCB New York team finished off 2005 with over $750 million in financing
for more than 270 area properties," stated Mr.
was provided by Helaba Bank in the amount of $145,400,000.
included $89.5 million in first mortgages plus $15.1 million in second mortgages and lines of credit.
Melody & Company's Stamford office team, comprised of Tim Harwood and Ron Roth, arranged more than $63 million in financings
throughout Connecticut in the first quarter 2005.
included $28.1 million in first mortgages, plus $14.7 million in second mortgages and lines of credit.