The Sale-Leaseback — The Gazetteer

Verification Limits

• Tax rules are summarized at teaching altitude. The sale-leaseback window, true-lease guidelines, §467 mechanics, recapture, and basis rules are stated without the exceptions and computational detail of the statute, regulations, and rulings. Qualification and characterization are facts-and-circumstances; nothing here substitutes for tax counsel on a real transaction.
• The leasing guidelines are guidelines. Rev. Proc. 2001-28 describes advance-ruling conditions, not substantive law; deals close outside its silhouette on opinion strength, and this gazetteer's "roughly 20%" formulations compress a nuanced body of authority.
• Market conventions are conventions. Descriptions of EBO placement, SLV construction, TIA architecture, guaranty scope, and structure-selection practice reflect common market behavior as of the August 2026 baseline, not the terms of any particular transaction.
• Cited statutes move. The credit statutes in particular (§§ 48E, 6418, and the OBBBA amendments) are under active implementation; the dated revision entries update the plate, but read the current instrument before acting.
• State law varies. Fixture characterization, filing mechanics, and property tax treatment are state-specific; portfolio work needs local counsel per jurisdiction.