This article was first published by Bloomberg BNA Daily Tax Report on February 24, 2014
In Private Letter Ruling 201404007, released Jan. 24, the Internal Revenue Service ruled favorably on a securitization structure to raise nonrecourse financing secured by cars subject to leases with a terminal rental adjustment clause (TRAC) provided for in Section 7701(h).
The full article is available here: IRS Blesses TRAC Lease Securitization 2-24-14 ready