FINANCING OF TENANT IMPROVEMENTS

• US 20110307364A2
• Filed: 07/07/2000
• Published: 12/15/2011
• Est. Priority Date: 07/07/1999
• Status: Active Application

• Current Assignee: TI Solutions LLC
• Original Assignee: TI Funding Group LLC
• Inventors: LOWENSTEIN, Douglas, CURWIN, Gary, Geitz, Robert
• Application Number:
  US09/611,548
• Publication Number:
  US 20050010517A1
• Time in Patent Office: Days
• US Class Current: 705/037
• CPC Class Codes: G06Q 40/02 Banking, e.g. interest calculation or account maintenance credit or loans G06Q40/03
• CPC Class Codes: G06Q 40/04 Trading; Exchange, e.g. stocks, commodities, derivatives or currency exchange

Abstract

Methods for lease financing of tenant improvements. Improvements to a lease space are leased from a special purpose entity to a tenant under an improvements lease distinct from the space lease. The special purpose entity may be a legal entity owned under tax accounting rules by a landlord of the space. Financial statements of the special purpose entity may be consolidated with the financial statements of the landlord. The special purpose entity may be capitalized by: (a) an equity investment by the landlord of at least three percent of the value of the tenant improvements and (b) debt issued by the special purpose entity of at least about eighty percent of the value of the tenant improvements, the debt being non-recourse against the special purpose entity, the landlord and the improvements and being secured by an absolute obligation of the tenant. The special purpose entity owns the improvements lease. Development of the tenant improvements may be financed by the special purpose entity. Rent payments under the improvements lease may have a present value at least equal to a value of the improvements at a time of commencement of the improvements lease. The improvements lease may be structured together with the space lease to support an accounting conclusion that the space lease and improvements lease are to be considered together as a single lease and classified as an operating lease. Rent payments under the improvements lease may be fully tax deductible to the tenant.

Claims

1. A method, comprising the steps of:

leasing a space from a landlord to a tenant under a space lease, the verb “

leasing”

meaning “

granting to another, or receiving a grant of from another, or taking hold of or holding by a lease from another, the possession and use of real or personal property, in return for present payment of or an obligation to pay rent or other consideration”

;

leasing tenant improvements to the space from a special purpose entity to the tenant under an improvements lease that is distinct from the space lease the special purpose entity being a legal entity owned under tax accounting rules by a landlord of the space, the special purpose entity owning the improvements lease;

development of the tenant improvements being financed by the special purpose entity, the special purpose entity being capitalized by;

(a) an equity investment by the landlord of at least three percent of the value of the tenant improvements and (b) debt issued by the special purpose entity of at least about eighty percent of the value of the tenant improvements, the debt being non-recourse against the special purpose entity, the landlord and the improvements and being secured by an absolute obligation of the tenant;

receiving a rent payment from the tenant to the special purpose entity under the improvements lease, the rent payments under the improvements lease having a present value at least equal to a value of the improvements at a time of commencement of the improvements lease;

the improvements lease being structured together with the space lease to support an accounting conclusion that the space lease and improvements lease are to be considered together as a single lease and classified as an operating lease under financial accounting rules or a true lease under tax accounting rules, financial statements of the special purpose entity being consolidated with financial statements of the landlord, rent payments under the improvements lease being fully tax deductible to the tenant;

at least some portion of the improvements lease being or having been performed by processing data in a non-transitory memory of a computer.

2. A method, comprising the steps of:

leasing a space from a landlord to a tenant under a space lease, the verb “

leasing”

meaning “

granting to another, or receiving a grant of from another, or taking hold of or holding by a lease from another, the possession and use of real or personal property, in return for present payment of or an obligation to pay rent or other consideration”

;

leasing improvements to the space to the tenant under an improvements lease that is distinct from the space lease, the improvements lease being structured together with the space lease to support an accounting conclusion that the space lease and improvements lease are to be considered together as a single lease and classified as an operating lease under financial accounting rules or a true lease under tax accounting rules;

at least some portion of the improvements lease being or having been performed by processing data in a non-transitory memory of a computer.

3. The method of claim 2, wherein:

the improvements are leased from a special purpose entity, the landlord of the space being the owner of, or lessor of the improvements to, the special purpose entity under tax accounting, financial statements of the special purpose entity being consolidated with financial statements of the landlord.

4. The method of claim 3, wherein:

rent payments under the improvements lease are fully tax deductible to the tenant.

5. The method of claim 3, wherein:

the improvements being financed by debt issued by the special purpose entity, the debt being non-recourse against the special purpose entity, the landlord and the improvements.

6. The method of claim 5, wherein the debt is secured by a rent obligation of the tenant under a lease of the improvements.

7. The method of claim 3, wherein:

the special purpose entity is capitalized by participations comprising;

(a) an equity investment by the landlord of at least three percent of the value of the improvements and (b) debt issued by the special purpose entity for at least about eighty percent of the value of the improvements.

8. The method of claim 3, wherein:

at least about 80% of the capitalization of the special purpose entity is a loan to the special purpose entity secured by a triple-net absolute obligation of the tenant.

9. The method of claim 8 wherein at least 3% of capitalization for the special purpose entity is a loan participation by the landlord.

10. The method of claim 8 wherein at least 10% of capitalization for the special purpose entity is contributed by the landlord.

11. The method of claim 8, wherein:

a majority of the loan to the special purpose entity is supplied by a party other than the landlord, and the landlord owns a participation in the loan made to the special purpose entity.

12. The method of claim 8:

wherein a building in which the space is located is encumbered by a mortgage;

and further comprising the step of, entry by the lender to the special purpose entity and a mortgagee of the mortgage into an inter-creditor agreement, each waiving any interest in the other'"'"'s collateral.

13. The method of claim 3, wherein the improvements have been constructed and are owned by the landlord, the tenant or jointly by landlord and tenant;

and further comprising the step of conveying or leasing the improvements to the special purpose entity before or concurrently with entry into the improvements lease.

14. The method of claim 3, wherein:

equity and/or debt investments by the landlord in a plurality of special purpose entities owned by the landlord, each special purpose entity owning improvements for lease to a corresponding tenant, are cross-collateralized.

15. The method of claim 3, wherein:

equity and/or debt investments by the landlord in a plurality of special purpose entities owned by the landlord, each special purpose entity owning improvements for lease to a corresponding tenant, are not cross-collateralized.

16. The method of claim 3, wherein:

the improvements being financed by debt issued by the special purpose entity, the debt being secured at least in part by a lien on the improvements.

17. The method of claim 3, wherein:

the improvements being financed by debt issued by the special purpose entity, the debt not being secured by a lien on the improvements.

18. The method of claim 2, wherein the special purpose entity is a limited liability company, grantor trust, business trust, corporation, limited partnership, or other business association.

19. The method of claim 2, wherein the special purpose entity has no ownership interest in any real property that includes the space.

20. The method of claim 2, wherein:

rent payments under the improvements lease have a present value at least equal to a value of the improvements at a time of commencement of the improvements lease.

21. The method of claim 2, the improvements being of balance-sheet for the tenant, financing for the improvements being related to the cost of funds of the tenant.

22. The method of claim 2, wherein financing for the improvements is provided by an entity other than the tenant.

23. The method of claim 2, further comprising the step of:

entry by the tenant into an obligation to construct the improvements and to assume costs associated with the construction.

24. The method of claim 2, wherein:

rent payments under the improvements lease are secured, in full or in part, by a personal or corporate guaranty or by a letter of credit of the tenant.

25. The method of claim 2, wherein:

the tenant is the only tenant in a building in which the space is located.

26. The method of claim 2, wherein the space is one of a plurality of spaces of a building divided for lease to a plurality of tenants, and the tenant is one of the plurality of tenants.

27. The method of claim 2, herein:

upon an event of default under the improvements lease, the tenant is obligated to purchase the improvements from the special purpose entity for a stipulated amount.

126. The method of claim 2, wherein:

the portion of the lease performed by processing data in a non-transitory memory of a computer includes formatting or buffering messages for transmission to or received from a potential lessor or lessee on a non-transitory network, or displaying data on a non-transitory display, the data providing a solicitation to enter the improvements lease.

127. The method of claim 2, wherein:

the portion of the improvements lease performed by processing data in a non-transitory memory of a computer includes formatting or buffering data for transmission to or received from a potential lessor or lessee over a non-transitory network, or displaying data on a non-transitory display, or storing data in a non-transitory memory, the data containing terms of the improvements lease and reflecting origination of the improvements lease.

128. The method of claim 2, wherein:

the portion of the improvements lease performed by processing data in a non-transitory memory of a computer includes formatting or buffering data for transmission to or received from the lessor, lessee or a servicer over a non-transitory network, or displaying data on a non-transitory display, or storing data in a non-transitory memory, the data containing terms of the improvements lease, the data being transmitted, displayed or stored on a computer of the lessor, lessee, or servicer under control of programs for managing or servicing the improvements lease.

129. The method of claim 2, herein:

the portion of the improvements lease performed by processing data in a non-transitory memory of a computer includes formatting or buffering data for transmission to or received from the lessor, lessee, investor or lender over a non-transitory network, or displaying data on a non-transitory display, or storing data in a non-transitory memory, the data containing terms of the improvements lease, the data being transmitted, displayed or stored on a computer of the lessor, lessee, investor or lender under control of programs for financial analysis of the improvements lease.

204. The method of claim 2, wherein

the improvements lease and the space lease arise in a lease document with distinct lease covenants covering the space lease and the improvements lease.

205. The method of claim 2, wherein:

the improvements lease and the space lease arise in an amendment or restructuring of a preexisting lease agreement to which the tenant, space landlord, and improvements landlord are parties.

28. A computer, programmed:

to solicit proposals from tenants for financing for tenant improvements to spaces leased by the respective tenants under respective space leases, each proposal offering terms for lease of tenant improvements to the corresponding space under an improvements that is lease distinct from the corresponding space lease, each improvements lease to be structured together with the corresponding space lease to support an accounting conclusion that the space lease and improvements lease are to be considered together as a single lease and classified as an operating lease under financial accounting rules or a true lease under tax accounting rules; and

to solicit offers of financing from lenders to the tenants'"'"' proposals, and notify the respective tenant and lender when an offer matches a proposal.

29. The computer of claim 28, being further programmed:

to solicit offers of financing using an auction protocol.

30. The computer of claim 28, being further programmed:

to store information on a plurality of tenant improvement loans closed between tenants and landlords, and to analyze the information.

31. A method, comprising the steps of:

leasing a space to a tenant, the verb “

leasing”

meaning “

granting to another, or receiving a grant of from another, or taking hold of or holding by a lease from another, the possession and use of real or personal property, in return for present payment of or an obligation to pay rent or other consideration”

; and

leasing improvements to the space from a special purpose entity to the tenant, a landlord of the space being the owner of, or lessor of the improvements to, the special purpose entity under tax accounting rules, financial statements of the special purpose entity being consolidated with financial statements of the landlord, rent payments under the improvements lease being fully tax deductible to the tenant;

at least some portion of the improvements lease being or having been performed by processing data in a non-transitory memory of a computer.

32. The method of claim 31, wherein:

the improvements are financed by debt issued by the special purpose entity the debt being non-recourse against the special purpose entity, the landlord and the improvements.

33. The method of claim 32, wherein the debt is secured by a rent obligation of the tenant under the improvements lease.

34. The method of claim 31, wherein:

rent payments under the improvements lease have a present value a least equal to a value of the improvements at a time of commencement of the improvements lease.

35. The method of claim 31, wherein:

the improvements lease is structured together with the space lease to support an accounting conclusion that the two leases are to be considered together as a single lease, classified as an operating lease under financial accounting rules or a true lease under tax accounting rules.

36. The method of claim 31, further comprising the step of:

capitalizing the special purpose entity by participations comprising;

(a) an equity investment by the landlord of at least three percent of the value of the improvements and (b) debt issued by the special purpose entity for at least about eighty percent of the value of the improvements.

37. The method of claim 31, wherein:

at least about 80% of the capitalization of the special purpose entity is a loan to the special purpose entity secured by a triple-net absolute obligation of the tenant.

38. The method of claim 37 wherein at least 10% of capitalization for the special purpose entity is contributed by the landlord.

39. The method of claim 37, wherein:

a majority of the loan to the special purpose entity is supplied by a party other than the landlord and tenant, and the landlord owns a participation in the loan made to the special purpose entity.

40. The method of claim 31

wherein a building in which the space is located is encumbered by a mortgage;

and

further comprising the step of, entry by the lender to the special purpose entity and a mortgagee of the mortgage into an inter-creditor agreement, each waiving any interest in the other'"'"'s collateral.

41. The method of claim 31, wherein the improvements have been constructed and are owned by the landlord, the tenant or jointly by landlord and tenant;

and further comprising the step of conveying or leasing the improvements to the special purpose entity before or concurrently with entry into the improvements lease.

42. The method of claim 31, wherein:

equity and/or debt investments by the landlord in a plurality of special purpose entities owned by the landlord, each special purpose entity owning improvements for lease to a corresponding tenant, are cross-collateralized.

43. The method of claim 31, wherein:

equity and/or debt investments by the landlord in a plurality of special purpose entities owned by the landlord, each special purpose entity owning improvements for lease to a corresponding tenant, are not cross-collateralized.

44. The method of claim 31, wherein the special purpose entity is a limited liability company, grantor trust, business trust, corporation, limited partnership, or other business association.

45. The method of claim 31, wherein the special purpose entity has no ownership interest in any real property that includes the space.

46. The method of claim 31, the improvements being off-balance-sheet for the tenant, financing for the improvements being related to the cost of funds of the tenant.

47. The method of claim 31, wherein financing for the improvements is provided by an entity other than the tenant.

48. The method of claim 31, further comprising the step of:

entry by the tenant into an obligation to construct the improvements and to assume costs associated with the construction.

49. The method of claim 31, wherein:

rent payments under the improvements lease are secured, in full or in part, by a personal or corporate guaranty or by a letter of credit of the tenant.

50. The method of claim 31, wherein:

the tenant is the only tenant in a building in which the space is located.

51. The method of claim 31, wherein the space is one of a plurality of spaces of a building divided for lease to a plurality of tenants, and the tenant is one of the plurality of tenants.

52. The method of claim 31, wherein:

upon an event of default under the improvements lease, the tenant is obligated to purchase the improvements from the special purpose entity for a stipulated amount.

53. A computer, programmed:

to solicit proposals from tenants for financing for tenant improvements to spaces leased by the respective tenants under respective space leases, each proposal offering terms for lease of tenant improvements to the corresponding space under an improvements lease distinct from the corresponding space lease, each improvements lease providing for lease of tenant improvements from a special purpose entity to the tenants a landlord of the space being the owner of, or lessor of the tenant improvements to, the special purpose entity under tax accounting rules, financial statements of the special purpose entity to be consolidated with financial statements of the landlord, rent payments under the improvements lease to be fully tax deductible to the tenant;

to solicit offers of financing from lenders to the tenants'"'"' proposals, and notify the respective tenant and lender when an offer matches a proposal.

54. The computer of claim 53, being further programmed:

to solicit offers of financing using an auction protocol.

55. The computer of claim 53, being further programmed:

to store information on a plurality of tenant improvement loans closed between tenants and landlords, and to analyze the information.

56. A method, comprising the steps of:

leasing an interest in real estate from a special purpose entity to a tenant, the verb “

leasing”

meaning “

granting to another, or receiving a grant of from another, or taking hold of or holding by a lease from another, the possession and use of real or personal property, in return for present payment of or an obligation to pay rent or other consideration”

, the special purpose entity being a legal entity owned by a landlord of the real estate that includes the leased interest, the special purpose entity owning the lease of the leased interest, development of an asset underlying the leased interest being financed by debt issued by the special purpose entity, the debt being non-recourse against the special purpose entity, the landlord and the asset;

at least some portion of the lease being or having been performed by processing data in a non-transitory memory of a computer.

57. The method of claim 56, wherein the interest leased is an interest in a shorter-lived asset, and further comprising the step of:

leasing a longer-lived asset to the tenant, rent payments under the lease of the shorter-lived asset having a present value at least equal to a cost of the shorter-lived asset at a time of commencement of the lease of the shorter-lived asset;

the lease to the shorter-lived asset being structured together with the lease to the longer-lived asset to support an accounting conclusion that the two leases are to be considered together as a single lease and classified as an operating lease under financial accounting rules or a true lease under tax accounting rules.

58. The method of claim 56, further comprising the step of:

leasing tenant improvements within a space from the special purpose entity to the tenant under the lease of claim 56, the special purpose entity being a legal entity owned, or leased the tenant improvements, by a landlord of the space, the special purpose entity being capitalized by participations comprising;

(a) an equity investment by the landlord of at least three percent of the value of the tenant improvements and (b) debt issued by the special purpose entity for at least about eighty percent of the value of the tenant improvements.

59. The method of claim 56, wherein the debt is secured by a triple-net absolute rent obligation of the tenant under a lease of the improvements.

60. A method, comprising the steps of:

leasing a longer-lived asset and a shorter-lived asset to a lessee under two separate leases, the verb “

leasing”

meaning “

granting to another, or receiving a grant of from another, or taking hold of or holding by a lease from another, the possession and use of real or personal property, in return for present payment of or an obligation to pay rent or other consideration”

, rent payments under the lease of the shorter-lived asset having a present value at least equal to a cost of the shorter-lived asset at a time of commencement of the lease of the shorter-lived asset;

at least some portion of the lease to the shorter-lived asset being structured together with the lease to the longer-lived asset to support an accounting conclusion that the two leases are to be considered together as a single lease, classified as an operating lease under financial accounting rules or a true lease under tax accounting rules;

at least some portion of leasing the shorter-lived asset being or having been performed by processing data in a non-transitory memory of a computer.

61. The method of claim 60, wherein:

the longer-lived asset is a space in a building; and

the shorter-lived asset is tenant improvements to the space.

62. The method of claim 61, wherein:

the tenant improvements are owned by a special purpose entity, being a legal entity owned by a landlord of the space.

63. The method of claim 62, further comprising the steps of:

capitalizing the special purpose entity by participations comprising;

(a) an equity investment by the landlord of at least three percent of the value of the tenant improvements and (b) debt issued by the special purpose entity for at least about eighty percent of the value of the tenant improvements.

64. The method of claim 62, wherein:

rent payments under the improvements lease fully tax deductible to the lessee.

65. The method of claim 62, Wherein:

the special purpose entity is capitalized by participations comprising;

(a) an equity investment by the landlord of at least three percent of the value of the tenant improvements and (b) debt issued by the special purpose entity for at least about eighty percent of the value of the tenant improvements.

66. The method of claim 62, wherein:

the building is divided for lease to multiple lessees.

67. The method of claim 66, wherein:

at least about 80% of the capitalization of the special purpose entity is a loan to the special purpose entity secured by a triple-net absolute obligation of the lessee.

68. The method of claim 62, wherein the tenant improvements have been constructed and are owned by the landlord, the lessee, or jointly by landlord and lessee;

and further comprising the step of conveying or leasing the tenant improvements to the special purpose entity before or concurrently with entry into the improvements lease.

69. The method of claim 62, wherein:

the landlord owns a plurality of special purpose entities, each owning tenant improvements for lease to a lessee.

70. The method of claim 62, wherein the special purpose entity has no ownership interest in any real property that includes the space.

71. The method of claim 61, the tenant improvements being off-balance-sheet for the lessee, financing for the improvements being related to the cost of funds of the lessee.

72. The method of claim 61, further comprising the step of:

entry by the lessee into an obligation to construct the tenant improvements and to assume costs associated with the construction.

73. The method of claim 61, wherein:

upon an event of default under the improvements lease, the lessee is obligated to purchase the improvements from the special purpose entity for a stipulated amount.

74. A method, comprising the steps of:

leasing tenant improvements within a space from a special purpose entity to a tenant, the verb “

leasing”

meaning “

granting to another, or receiving a grant of from another, or taking hold of or holding by a lease from another, the possession and use of real or personal property, in return for present payment of or an obligation to pay rent or other consideration”

, the special purpose entity being a legal entity owned by a landlord of the space, the special purpose entity being capitalized by participations comprising;

(a) an equity investment by the landlord of at least three percent of the value of the tenant improvements and (b) debt issued by the special purpose entity for at least about eighty percent of the value of the tenant improvements;

at least some portion of the tenant improvements lease being or having been performed by processing data in a non-transitory memory of a computer.

75. The method of claim 74, wherein:

the building is divided for lease to multiple tenants, at least about 80% of the capitalization of the special purpose entity being a loan to the special purpose entity secured by a triple-net absolute obligation of the tenant.

76. The method of claim 75 wherein at least 3% of capitalization for the special purpose entity is a loan participation by the landlord.

77. The method of claim 75:

wherein a building in which the space is located is encumbered by a mortgage; and

and further comprising the step of, entry by the lender to the special purpose entity and a mortgagee of the mortgage into an inter-creditor agreement, each waiving any interest in the other'"'"'s collateral.

78. The method of claim 74, wherein:

financial statements of the special purpose entity are consolidated with financial statements of the landlord.

79. The method of claim 78, wherein:

rent payments under the improvements lease are fully tax deductible to the tenant.

80. The method of claim 78, wherein:

the tenant improvements being financed by debt issued by the special purpose entity, the debt being non-recourse against the special purpose entity, the landlord and the tenant improvements.

81. The method of claim 80, wherein the debt is secured by a triple-net absolute rent obligation of the tenant under a lease of the tenant improvements.

82. The method of claim 78, wherein:

the tenant improvements have been constructed and are owned by the landlord, the tenant or jointly by landlord and tenant;

and further comprising the step of conveying or leasing the tenant improvements to the special purpose entity before or concurrently with entry into the improvements lease.

83. The method of claim 78, wherein:

the tenant improvements being financed by debt issued by the special purpose entity, the debt not being secured by a lien on the tenant improvements.

84. The method of claim 74, wherein the special purpose entity is a limited liability company or limited partnership.

85. The method of claim 74, wherein the special purpose entity is a grantor trust or business trust.

86. The method of claim 74, wherein the special purpose entity is a corporation.

87. The method of claim 74, wherein the special purpose entity has no ownership interest in any real property that includes the space.

88. The method of claim 74, the tenant improvements being off-balance-sheet for the tenant, financing for the tenant improvements being related to the cost of funds of the tenant.

89. The method of claim 74, wherein financing for the tenant improvements is provided by an entity other than the tenant.

90. The method of claim 74, wherein:

the tenant is the only tenant in a building in which the space is located.

91. The method of claim 74, wherein the space is one of a plurality of spaces of a building divided for lease to a plurality of tenants, and the tenant is one of the plurality of tenants.

92. The method of claim 74, wherein:

upon an event of default under the improvements lease, the tenant is obligated to purchase the tenant improvements from the special purpose entity for a stipulated amount.

93. A method, comprising the steps of:

leasing an interest in a space from a special purpose entity to a tenant, the verb “

leasing”

meaning “

granting to another, or receiving a grant of from another, or taking hold of or holding by a lease from another, the possession and use of real or personal property, in return for present payment of or an obligation to pay rent or other consideration”

, the special purpose entity being a legal entity owned by a landlord of the building including the space, the building being divided for lease to multiple tenants, at least about 80% of the capitalization of the special purpose entity being a loan to the special purpose entity secured by an absolute obligation of the tenant;

at least some portion of the lease of the interest being or having been performed by processing data in a non-transitory memory of a computer.

94. The method of claim 93, wherein the interest is a possessory interest in improvements to the space, the space being leased to the tenant under a separate lease, rent payments under the improvements lease having a present value at least equal to a cost of the improvements at a time of commencement of the improvements lease.

95. The method of claim 94, further comprising the step of:

structuring the improvements lease together with the space lease to support an accounting conclusion that the two leases are to be considered together as a single lease, classified as an operating lease under financial accounting rules or a true lease under tax accounting rules.

96. The method of claim 93 wherein at least 3% of capitalization for the special purpose entity is a loan participation by the landlord.

97. The method of claim 93 wherein at least 10% of capitalization for the special purpose entity is contributed by the landlord.

98. The method of claim 93, wherein:

a majority of the loan to the special purpose entity is supplied by a party other than the landlord, and the landlord owns a participation in the loan made to the special purpose entity.

99. The method of claim 93, wherein:

the improvements are financed by debt issued by the special purpose entity, the debt not being secured by a lien on the improvements.

100. The method of claim 93, wherein the special purpose entity is a limited liability company, grantor trust, business trust, corporation, limited partnership, or other business association.

101. The method of claim 93, wherein financing for the improvements is provided by an entity other than the tenant.

102. A method, comprising the steps of:

improving a space, financing for the improvements being provided by an entity other than a tenant of the space, financing for the improvements being obtained at the tenant'"'"'s cost of funds;

leasing the space from a landlord to the tenant under a space lease, the verb “

leasing”

meaning “

granting to another, or receiving a grant of from another, or taking hold of or holding by a lease from another, the possession and use of real or personal property, in return for present payment of or an obligation to pay rent or other consideration”

; and

leasing the improvements to the tenant under an improvements lease that is distinct from the space lease;

at least some portion of the improvements lease being or having been performed by processing data in a non-transitory memory of a computer.

103. The method of claim 102, wherein:

the improvements are leased from a special purpose entity, the landlord of the space being the owner of, or lessor of the improvements to, the special purpose entity under tax accounting, financial statements of the special purpose entity being consolidated with financial statements of the landlord.

104. The method of claim 102, wherein:

rent payments under the improvements lease are fully tax deductible to the tenant.

105. The method of claim 103, wherein:

the improvements being financed by debt issued by the special purpose entity, the debt being non-recourse against the special purpose entity, the landlord and the improvements.

106. The method of claim 105, wherein the debt is secured by a rent obligation of the tenant under a lease of the improvements.

107. The method of claim 103, wherein:

the special purpose entity is capitalized by participations comprising;

(a) an equity investment by the landlord of at least three percent of the value of the improvements and (b) debt issued by the special purpose entity for at least about eighty percent of the value of the improvements.

108. The method of claim 103, wherein:

at least about 80% of the capitalization of the special purpose entity is a loan to the special purpose entity secured by a triple-net absolute obligation of the tenant.

109. The method of claim 108, herein:

a majority of the loan to the special purpose entity is supplied by a party other than the landlord, and the landlord owns a participation in the loan made to the special purpose entity.

110. The method of claim 108:

wherein a building in which the space is located is encumbered by a mortgage;

and further comprising the step of, entry by the lender to the special purpose entity and a mortgagee of the mortgage into an inter-creditor agreement, each waiving any interest in the other'"'"'s collateral.

111. The method of claim 103, herein the improvements have been constructed and are owned by the landlord, the tenant or jointly by landlord and tenant;

and further comprising the step of conveying or leasing the improvements to the special purpose entity before or concurrently with entry into the improvements lease.

112. The method of claim 103, wherein:

the improvements being financed by debt issued by the special purpose entity, the debt being secured at least in part by a lien on the improvements.

113. The method of claim 103, herein:

upon an event of default under the improvements lease, the tenant assumes an obligation to purchase the improvements from the special purpose entity for a stipulated amount.

114. The method of claim 102, wherein:

the improvements lease is structured together with the space lease to support an accounting conclusion that the improvements lease is to be classified as an operating lease under financial accounting rules or a true lease under tax accounting rules.

115. The method of claim 102, wherein:

rent payments under the improvements lease have a present value at least equal to a value of the improvements at a time of commencement of the improvements lease.

116. The method of claim 102, the improvements being off-balance-sheet for the tenant.

117. The method of claim 102, further comprising the step of:

entry by the tenant into an obligation to construct the improvements and to assume costs associated with the construction.

118. The method of claim 102, wherein:

rent payments under the improvements lease are secured, in full or in part, by a personal or corporate guaranty or by a letter of credit of the tenant.

119. A method, comprising the steps of:

leasing an interest in real estate from a special purpose entity to a tenant, the verb “

leasing”

meaning “

granting to another, or receiving a grant of from another, or taking hold of or holding by a lease from another, the possession and use of real or personal property, in return for present payment of or an obligation to pay rent or other consideration”

, the special purpose entity being a legal entity distinct from a landlord of the real estate that includes the leased interest, the landlord having sufficient ownership in the special purpose entity to establish the landlord'"'"'s genuine economic risk in the lease, the special purpose entity owning the lease of the leased interest, development of an asset underlying the leased interest being financed by debt issued by the special purpose entity, the debt being non-recourse against the special purpose entity, the landlord and the asset;

at least some portion of the lease being or having been performed by processing data in a non-transitory memory of a computer, the data representing at least one of a group consisting of (a) the landlord, the (b) tenant, and (e) a primary investor, secondary investor, or lender, who contributed capital to the asset or to an entity owning the asset.

120. The method of claim 119, further comprising the steps of:

leasing a space from the landlord to the tenant under a space lease;

leasing improvements to the space from the special purpose entity to the tenant under the lease of claim 119, being an improvements lease that is distinct from the space lease, the improvements lease being structured together with the space lease to support an accounting conclusion that the space lease and improvements lease are to be considered together as a single lease and classified as an operating lease under financial accounting rules or a true lease under tax accounting rules.

121. The method of claim 119, further comprising the steps of:

leasing a space from the landlord to the tenant under a space lease;

leasing improvements to the space from a special purpose entity to the tenant under the lease of claim 119, being an improvements lease that is distinct from the space lease, the landlord of the space being the owner of, or lessor of the improvements to, the special purpose entity under tax accounting rules, financial statements of the special purpose entity being consolidated with financial statements of the landlord, rent payments under the improvements lease being fully tax deductible to the tenant.

122. The method of claim 119, wherein the interest leased is an interest in a shorter-lived asset, and further comprising the step of:

leasing a longer-lived asset to the tenant, rent payments under the lease of the shorter-lived asset having a present value at least equal to a cost of the shorter-lived asset at a time of commencement of the lease of the shorter-lived asset;

the lease to the shorter-lived asset being structured together with the lease to the longer-lived asset to support an accounting conclusion that the two leases are to be considered together as a single lease and classified as an operating lease under financial accounting rules or a true lease under tax accounting rules.

123. The method of claim 119, further comprising the step of:

leasing tenant improvements within a space from a special purpose entity to a tenant under the lease of claim 119, the special purpose entity being a legal entity owned, or leased the tenant improvements, by a landlord of the space, the special purpose entity being capitalized by participations comprising;

(a) an equity investment by the landlord of at least three percent of the value of the tenant improvements and (b) debt issued by the special purpose entity for at least about eighty percent of the value of the tenant improvements.

124. The method of claim 119, wherein:

the special purpose entity is a legal entity owned by a landlord of a building, the building being divided for lease to multiple tenants, at least about 80% of the capitalization of the special purpose entity being a loan to the special purpose entity secured by an absolute obligation of the tenant.

125. The method of claim 119, further comprising the steps of:

improving a space, financing for the improvements being provided by an entity other than a tenant of the space, financing for the improvements being obtained at the tenant'"'"'s cost of funds;

leasing the space from the landlord to the tenant under a space lease; and

leasing the improvements to the tenant under the lease of claim 119, being an improvements lease that is distinct from the space lease.

130. A method, comprising the steps of:

leasing tenant improvements within a space from a special purpose entity to a tenant under a tenant improvements lease, the landlord of the space having sufficient ownership in the special purpose entity to establish the landlord'"'"'s genuine economic risk in the tenant improvements lease, the special purpose entity being capitalized by participations comprising;

(a) an equity investment by the landlord of at least three percent of the value of the tenant improvements and (b) debt issued by the special purpose entity for at least about eighty percent of the value of the tenant improvements;

at least some portion of the tenant improvements lease being or having been performed by processing data in a non-transitory memory of a computer, data processed by the computer representing at least one of a group consisting of (a) the landlord, (b) the tenant, and (c) a primary investor, secondary investor, or a lender, who contributed capital to the tenant improvements or to an entity owning the tenant improvements.

131. The method of claim 130, wherein:

the building is divided for lease to multiple tenants, at least about 80% of the capitalization of the special purpose entity being a loan to the special purpose entity secured by a triple-net absolute obligation of the tenant.

132. The method of claim 131 wherein at least 3% of capitalization for the special purpose entity is a loan participation by the landlord.

133. A method, comprising the steps of:

receiving a rent payment under a lease of a space from a landlord to a tenant under a space lease;

receiving a rent payment under a lease of improvements to the space to the tenant under an improvements lease that is distinct from the space lease, the improvements lease being structured together with the space lease to support an accounting conclusion that the space lease and improvements lease are to be considered together as a single lease and classified as an operating lease under financial accounting rules or a true lease under tax accounting rules;

at least some portion of the improvements lease being or having been performed by processing data in a non-transitory memory of a computer, the data representing at least one of a group consisting of (a) the landlord, (b) the tenant, and (c) a primary investor, secondary investor, or lender, who contributed capital to the set or to an entity owning the improvements.

134. The method of claim 133, wherein:

the improvements are leased from a special purpose entity, the landlord of the space being the owner of, or lessor of the improvements to, the special purpose entity under tax accounting, financial statements of the special purpose entity being consolidated with financial statements of the landlord.

135. The method of claim 134, wherein:

rent payments under the improvements lease are fully tax deductible to the tenant.

136. The method of claim 134, wherein:

the improvements being financed by debt issued by the special purpose entity, the debt being non-recourse against the special purpose entity, the landlord and the improvements.

137. The method of claim 134, wherein:

the special purpose entity is capitalized by participations comprising;

(a) an equity investment by the landlord of at least three percent of the value of the improvements and (b) debt issued by the special purpose entity or at least about eighty percent of the value of the improvements.

138. The method of claim 134, wherein:

at least about 80% of the capitalization of the special purpose entity is a loan to the special purpose entity secured by a triple-net absolute obligation of the tenant.

139. The method of claim 133, wherein:

rent payments under the improvements lease have a present value at least equal to a value of the improvements at a time of commencement of the improvements lease.

140. A method, comprising the steps of:

receiving a rent payment under a lease of a space to a tenant; and

receiving a rent payment under a lease of improvements to the space from a special purpose entity to the tenant, a landlord of the space being the owner of, or lessor of the improvements to, the special purpose entity under tax accounting rules, financial statements of the special purpose entity being consolidated with financial statements of the landlord, rent payments under the improvements lease being fully tax deductible to the tenant;

at least some portion of the improvements lease being or having been performed by processing data in a non-transitory memory of a computer, data processed by the computer representing at least one of a group consisting of the landlord, the tenant, a dollar amount of a transaction, and a loan purchaser.

141. The method of claim 140, wherein:

the improvements are financed by debt issued by the special purpose entity, the debt being non-recourse against the special purpose entity, the landlord and the improvements.

142. The method of claim 140, wherein:

rent payments under the improvements lease have a present value at least equal to a value of the improvements at a time of commencement of the improvements lease.

143. The method of claim 140, wherein:

the improvements lease is structured together with the space lease to support an accounting conclusion that the two leases are to be considered together as a single lease, classified as an operating lease under financial accounting rules or a true lease under tax accounting rules.

144. The method of claim 140, further comprising the step of:

capitalizing the special purpose entity by participations comprising;

(a) an equity investment by the landlord of at least three percent of the vale of the improvements and (b) debt issued by the special purpose entity for at least about eighty percent of the value of the improvements.

145. The method of claim 140, wherein:

at least about 80% of the capitalization of the special purpose entity is a loan to the special purpose entity secured by a triple-net absolute obligation of the tenant.

146. The method of claim 140, wherein the special purpose entity has no ownership interest in any real property that includes the space.

147. The method of claim 140, wherein:

upon an event of default under the improvements lease, the tenant is obligated to purchase the improvements from the special purpose entity for a stipulated amount.

148. A method, comprising the steps of:

receiving a rent payment under leases of a longer-lived asset and a shorter-lived asset to a lessee under two separate leases, rent payments under the lease of the shorter-lived asset having a present value at least equal to a cost of the shorter-lived asset at a time of commencement of the lease of the shorter-lived asset;

the lease to the shorter-lived asset being structured together with the lease to the longer-lived asset to support an accounting conclusion that the two leases are to be considered together as a single leases classified as an operating lease under financial accounting rules or a true lease under tax accounting rules;

at least some portion of leasing the shorter-lived asset being or having been performed by processing data in a non-transitory memory of a computer, data processed by the computer representing at least one of a group consisting of a lessor, the lessee, a dollar amount of a transaction, and a loan purchaser.

149. The method of claim 148, wherein:

the longer-lived asset is a space in a building; and

the shorter-lived asset is tenant improvements to the space.

150. The method of claim 149, further comprising the steps of:

capitalizing a special purpose entity, being a legal entity owned by a landlord of the space, by participations comprising;

(a) an equity investment by the landlord of at least three percent of the value of the tenant improvements and (b) debt issued by the special purpose entity for at least about eighty percent of the value of the tenant improvements.

151. The method of claim 150, wherein:

at least about 80% of the capitalization of the special purpose entity is a loan to the special purpose entity secured by a triple-net absolute obligation of the lessee.

152. The method of claim 148, wherein:

rent payments under the lease to the shorter-lived asset are fully tax deductible to the lessee.

153. The method of claim 148, wherein:

the longer-lived asset is space in a building divided for lease to multiple lessees.

154. A method, comprising the steps of:

receiving a rent payment under a lease of tenant improvements within a space from a special purpose entity to a tenant, the landlord having sufficient ownership in the special purpose entity to establish the landlord'"'"'s genuine economic risk in the tenant improvements lease, the special purpose entity being capitalized by participations comprising;

(a) an equity investment by the landlord of at least three percent of the value of the tenant improvements and (b) debt issued by the special purpose entity for at least about eighty percent of the value of the tenant improvements;

at least some portion of the tenant improvements lease being or having been performed by processing data in a non-transitory memory of a computer, data processed by the computer representing at least one of a group consisting of (a) the landlord, (b) the tenant, (c) a dollar amount of a transaction, and (d) a loan purchaser.

155. The method of claim 154, wherein:

the building is divided for lease to multiple tenants, at least about 80% of the capitalization of the special purpose entity being a loan to the special purpose entity secured by a triple-net absolute obligation of the tenant.

156. The method of claim 154, wherein:

rent payments under the tenant improvements lease are fully tax deductible to the tenant.

157. The method of claim 154, wherein:

the tenant improvements being financed by debt issued by the special purpose entity, the debt being non-recourse against the special purpose entity, the landlord and the tenant improvements.

158. A method, comprising the steps of:

receiving a rent payment under a lease of an interest in a space from a special purpose entity to a tenant, the special purpose entity being a legal entity owned by a landlord of the building including the space, the building being divided for lease to multiple tenants, at least about 80% of the capitalization of the special purpose entity being a loan to the special purpose entity secured by an absolute obligation of the tenant;

a least some portion of the lease of the interest being or having been performed by processing data in a non-transitory memory of a computer, data processed by the computer representing at least one of a group consisting of the landlord, the tenant, a dollar amount of a transaction, and a loan purchaser.

159. The method of claim 158, wherein the interest is a possessory interest in improvements to the space, the space being leased to the tenant under a separate lease, rent payments under the improvements lease having a present value at least equal to a cost of the improvements at a time of commencement of the improvements lease.

160. The method of claim 159, further comprising the step of:

structuring the improvements lease together with the space lease to support an accounting conclusion that the two leases are to be considered together as a single lease, classified as an operating lease under financial accounting rules or a true lease under tax accounting rules.

161. A method, comprising the steps of:

improving a space, financing for the improvements being provided by an entity other than a tenant of the space, financing for the improvements being obtained at the tenant'"'"'s cost of funds;

receiving a rent patent under a lease of the space from a landlord to the tenant under a space lease; and

receiving a rent pay ent under a lease of the improvements to the tenant under an improvements lease that is distinct from the space lease;

at least some portion of the improvements lease being or having been performed by processing data in a non-transitory memory of a computers data processed by the computer representing at least one of a group consisting of the landlord, the tenant, a dollar amount of a transaction, and a loan purchaser.

162. The method of claim 161, wherein:

the improvements leased from a special purpose entity, the landlord of the space being the owner of, or lessor of the improvements to, the special purpose entity under tax accounting, financial statements of the special purpose entity being consolidated with financial statements of the landlord.

163. The method of claim 161, wherein:

rent payments under the improvements lease are fully tax deductible to the tenant.

164. The method of claim 162, wherein:

the improvements being financed by debt issued by the special purpose entity, the debt being non-recourse against the special purpose entity, the landlord and the improvements.

165. The method of claim 164, wherein the debt is secured by a rent obligation of the tenant under a lease of the improvements.

166. The method of claim 162, wherein:

the special purpose entity is capitalized by participations comprising;

(a) an equity investment by the landlord of at least three percent of the value of the improvements and (b) debt issued by the special purpose entity for at least about eighty percent of the value of the improvements.

167. The method of claim 162, wherein:

at least about 80% of the capitalization of the special purpose entity is a loan to the special purpose entity secured by a triple-net absolute obligation of the tenant.

168. The method of claim 167, wherein:

a majority of the loan to the special purpose entity is supplied by a party other than the landlord, and the landlord owns a participation in the loan made to the special purpose entity.

169. The method of claim 162, wherein:

the improvements being financed by debt issued by the special purpose entity, the debt being secured at least in part by a lien on the improvements.

170. The method of claim 161, wherein:

the improvements lease is structured together with the space lease to support an accounting conclusion that the improvements lease is to be classified as an operating lease under financial accounting rules or a true lease under tax accounting rules.

171. The method of claim 161, wherein:

rent payments under the improvements lease have a present value at least equal to a value of the improvements at a time of commencement of the improvements lease.

172. A method, comprising the steps of:

receiving a rent payment under a lease of an interest in real estate from a special purpose entity to a tenant, the special purpose entity being a legal entity distinct from a landlord of the real estate that includes the leased interest, the landlord having sufficient ownership in the special purpose entity to establish the landlord'"'"'s genuine economic risk in the lease, the special purpose entity owning the lease of the leased interest, development of an asset underlying the leased interest being financed by debt issued by the special purpose entity, the debt being non-recourse against the special purpose entity, the landlord and the asset;

a least some portion of the lease being or having been performed by processing data in a non-transitory memory of a computer, data processed by the computer representing at least one of a group consisting of the landlord, the tenant, the special purpose entity, a dollar amount of a transaction, and a loan purchaser.

173. The method of claim 172, further comprising the steps of:

receiving a rent payment under a lease of a space from the landlord to the tenant under a space lease;

receiving a rent payment under a lease of improvements to the space from the special purpose entity to the tenant under the lease of claim 172, being an improvements lease that is distinct from the space lease, the improvements lease being structured together with the space lease to support an accounting conclusion that the space lease and improvements lease are to be considered together as a single lease and classified as an operating lease.

174. The method of claim 172, further comprising the steps of:

receiving a rent payment under a lease of a space from the landlord to the tenant under a space lease;

receiving a rent payment under a lease of improvements to the space from a special purpose entity to the tenant under the lease of claim 172, being an improvements lease that is distinct from the space lease, the landlord of the space being the owner of, or lessor of the improvements to, the special purpose entity under tax accounting rules, financial statements of the special purpose entity being consolidated with financial statements of the landlord, rent payments under the improvements lease being fully tax deductible to the tenant.

175. The method of claim 172, wherein the interest leased is an interest in a shorter-lived asset, and further comprising the step of:

receiving a rent payment under a lease of a longer-lived asset to the tenant, rent payments under the lease of the shorter-lived asset having a present value at least equal to a cost of the shorter-lived asset at a time of commence ent of the lease of the shorter-lived asset;

the lease to the shorter-lived asset being structured together with the lease to the longer-lived asset to support an accounting conclusion that the two leases are to be considered together as a single lease and classified as an operating lease under financial accounting rules or a true lease under tax accounting rules.

176. The method of claim 172, further comprising the step of:

receiving a rent payment under a lease of tenant improvements within a space from a special purpose entity to a tenant under the lease of claim 172, the special purpose entity being a legal entity owned, or leased the tenant improvements, by a landlord of the space, the special purpose entity being capitalized by participations comprising;

(a) an equity investment by the landlord of at least three percent of the value of the tenant improvements and (b) debt issued by the special purpose entity for at least about eighty percent of the value of the tenant improvements.

177. The method of claim 172, wherein:

the special purpose entity is a legal entity owned by a landlord of a building, the building being divided for lease to multiple tenants, at least about 80% of the capitalization of the special purpose entity being a loan to the special purpose entity secured by an absolute obligation of the tenant.

178. The method of claim 172, further comprising the steps of:

improving a space, financing for the improvements being provided by an entity other than a tenant of the space, financing for the improvements being obtained at the tenant'"'"'s cost of funds;

receiving a rent payment under a lease of the space from the landlord to the tenant under a space lease; and

receiving a rent payment under a lease of the improvements to the tenant under the lease of claim 172, being an improvements lease that is distinct from the space lease.

179. A method, comprising the steps of:

leasing a space from a landlord to a tenant under a space lease, the verb “

leasing”

meaning “

granting to another, or receiving a grant of from another, or taking hold of or holding by a lease from another, the possession and use of real or personal property, in return for present payment of or an obligation to pay rent or other consideration”

;

leasing improvements to the space to the tenant under an improvements lease that is [a] distinct from the space lease and [b] structured together with the space lease to support an accounting conclusion that [b][1] the space lease and improvements lease are to be considered together as a single lease and [b][2] classified as an operating lease under financial accounting rules or a true lease under tax accounting rules, and [c] at least some portion of the improvements lease being or having been performed by processing data in a non-transitory memory of a computer.

180. A method, comprising the steps of:

leasing a space from a landlord to a tenant under a space lease, the verb “

leasing”

meaning “

granting or maintaining a grant to another, or receiving a grant of from another, or taking hold of or holding by a lease from another, the possession and use of real or personal property, in return for present payment of or an obligation to pay rent or other consideration”

;

leasing improvements to the space to the tenant under an improvements lease that is distinct from the space lease;

the improvements lease and the space lease being consolidated together as a single operating lease under financial accounting rules or a true lease under tax accounting rules;

at least some portion of soliciting, originating, managing, or analyzing the improvements lease being or having been performed by processing data in a non-transitory memory of a computer.

181. A computer system, comprising:

hardware and software designed to assist a tenant in entering an improvements lease, the improvements lease to grant the tenant possession and use of improvements to a space leased to the tenant under a space lease that is distinct from the improvements lease;

a non-transitory memory storing data providing that the space lease and improvements lease are to be consolidated together as a single lease for financial accounting; and

a non-transitory memory storing data providing that, for financial accounting, the consolidated lease is to be treated as an operating lease under financial accounting rules or a true lease under tax accounting rules.

182. One or more non-transitory memories, having stored thereon computer programs and/or data to cause at least one computers to:

process a payment on a lease for improvements to a space, financing for the improvements being provided by an entity other than a tenant of the space, financing for the improvements being obtained at the tenant'"'"'s cost of funds, the space being leased from a landlord to the tenant under a space lease, the improvements lease being distinct from the space lease, at least some portion of the programs and/or data reflecting a characteristic of the improvements lease or the interrelationship between the space and improvements leases.

183. A method comprising the steps of:

processing data in a non-transitory memory of a computer, the processing reflecting paying or receiving a payment on a lease granting rights to use tenant improvements to a tenant, the tenant improvements being improvements to a space leased to the tenant, financing or ownership of the tenant improvements being distinct from financing or ownership of the space, an amount of the payment payable to a tenant improvements payee for lease of the tenant improvements being segregable from an amount payable to a distinct space payee for lease of the space, the segregation reflecting the distinct ownership or financing, the lease of the improvements and the lease of the space lease being structured to support an accounting conclusion that the leasing of the space lease and the leasing of the tenant improvements are to be considered together as a single lease and classified as an operating lease under financial accounting rules or a true lease under tax accounting rules;

the processed data representing at least one of a group consisting of (a) the lessor of the space, (b) the lessor of the tenant improvements, (c) the tenant, and (d) a primary investor, secondary investor, or lender, who contributed capital to the improvements or to an entity owing the improvements.

184. The method of claim 183, wherein:

the segregable amounts paid for lease of the tenant improvements are fully tax deductible to the tenant.

185. The method of claim 183, wherein:

the tenant improvements were financed by debt issued by a special purpose entity, the debt being non-recourse against the special purpose entity the landlord and the improvements.

186. The method of claim 185, wherein:

the debt is secured by a lien on the segregable payments for lease of the tenant improvements.

187. The method of claim 185, wherein:

at least about 80% of the capitalization of the special purpose entity is a loan to the special purpose entity secured by a triple-net absolute obligation of the tenant.

188. The method of claim 183, wherein:

the present value of segregable amounts paid for lease of the tenant improvements are at least equal to a value of the tenant improvements at a time of commencement of the lease of the tenant improvements.

189. The method of claim 183, wherein:

financing for the tenant improvements was provided by an entity other than the tenant of the space, the tenant improvements financing being obtained at the tenant'"'"'s cost of funds;

190. The method of claim 183, wherein

the lease of the tenant improvements and the lease of the space arise in a lease document with distinct lease covenants covering the space lease and the tenant improvements lease.

191. The method of claim 183, wherein

the lease of the tenant improvements and the lease of the space arise in an amendment or restructuring of a preexisting lease agreement.

192. The method of claim 183:

the segregable amount of the payment payable to a tenant improvements payee being paid into a payment distribution agent for distribution of segregable amounts to appropriate payees.

193. A method comprising the steps of:

processing data in a non-transitory memory of a computer, the processing reflecting paying or receiving a payment on a lease granting rights to use a shorter-lived asset to a lessee, the shorter-lived asset being functionally related to a longer-lived asset also leased to the lessee, financing or ownership of the shorter-lived asset being distinct from financing or ownership of the longer-lived asset, an amount of the payment payable by the lessee to a payee for the shorter-lived asset for lease of the shorter-lived asset being segregable from an amount payable by the lessee to a distinct payee for lease of the longer-lived asset, the segregation reflecting the distinct ownership or financing,

the segregable payment stream directed to the shorter-lived asset having a present value at least equal to a cost of the shorter-lived asset at a time of commencement of the lease covering the shorter-lived asset;

at least some portion of the lease to the shorter lived asset being structured together with the lease to the longer-lived asset to support an accounting conclusion that the two leases are to be considered together as a single lease, classified as an operating lease under financial accounting rules or a true lease under tax accounting rules.

194. The method of claim 193, wherein:

rent payments under the shorter-lived asset lease are fully tax deductible to the lessee.

195. The method of claim 193, wherein:

the shorter-lived asset was financed by debt issued by a special purpose entity, the debt being non-recourse against the special purpose entity, the lessor and the shorter-lived asset.

196. The method of claim 193, wherein:

at least about 80% of the capitalization of the special purpose entity is a loan to the special purpose entity secured by a triple-net absolute obligation of the lessee.

197. A method comprising the steps of:

processing data in a non-transitory memory of a computers the processing reflecting paying or receiving a payment on a lease granting rights to use tenant improvements to a tenant, the tenant improvements being improvements to a space leased to the tenant, financing or ownership of the tenant improvements being distinct from financing or ownership of the space, an amount of the payment payable to a tenant improvements payee for lease of the tenant improvements being segregable from an amount payable to a distinct space payee for lease of the space, the segregation reflecting the distinct ownership or financing;

financing for the tenant improvements being provided by an entity other than a tenant of the space, financing for the tenant improvements being obtained at the tenant'"'"'s cost of funds;

the processed data representing at least one of a group consisting of (a) the lessor of the space, (b) the lessor of the tenant improvements, (c) the tenant, and (d) a primary investor, secondary investor, or lender, who contributed capital to the improvements or to an entity owing the improvements.

198. The method of claim 197, wherein:

the lease of the improvements and the lease of the space lease is structured to support an accounting conclusion that the leasing of the space lease and the leasing of the tenant improvements are to be considered together as a single lease and classified as an operating lease under financial accounting rules or a true lease under tax accounting rules.

199. The method of claim 197, wherein:

the segregable amounts paid for lease of the tenant improvements are fully tax deductible to the tenant.

200. The method of claim 197, wherein:

the tenant improvements were financed by debt issued by a special purpose entity, the debt being non-recourse against the special purpose entity, the landlord and the improvements.

201. The method of claim 197, wherein:

the debt is secured by a lien on the segregable payments for lease of the tenant improvements.

202. The method of claim 197, wherein:

at least about 80% of the capitalization of the special purpose entity is a loan to the special purpose entity secured by a triple-net absolute obligation of the tenant.

203. The method of claim 197, wherein:

the present value of segregable amounts paid for lease of the tenant improvements are at least equal to a value of the tenant improvements at a time of commencement of the lease of the tenant improvements.