Utilities as lessors in tax-benefit-transfer leases

The Economic Recovery Tax Act of 1981 contains provisions which allow the transfer between corporate taxpayers of certain deductions and investment tax credits through special lease provisions. These lease provisions enable a company whose taxable income is relatively large to reduce its tax liability by obtaining entitlement to these tax benefits from a company with minor tax liabilities. This article describes the analytical framework by which one utility company determines whether resultant economic benefits justify its becoming a buyer of such tax benefits by becoming a lessor of the equipment giving rise to the tax benefits. 3 figures, 2 tables.