Five Deal Structures. One Practice. The Right Fit for You.
Every investor has different goals. We offer five distinct investment structures — from tax-advantaged equity to secured debt — and tailor each deal to your specific situation.
Every investor has different goals. We offer five distinct investment structures — from tax-advantaged equity to secured debt — and tailor each deal to your specific situation.
Click to jump to the structure that interests you, or scroll through all five.
⚠️ Expired 12/31/2025 — CREATES Act Pending
Under IRC Section 181, an investor purchases an ownership interest in a single-purpose entity (SPV) that holds the film’s copyright. The acquisition is structured as a combination of cash and a long-term purchase money note, with the specific split negotiated deal-by-deal based on the investor’s tax position and the film’s capital needs.
The investor immediately deducts the full purchase price of the film interest against ordinary income in the year of investment. This means the deduction can significantly exceed the cash outlay.
On a $1M total purchase price, the investor takes an immediate $1M deduction against ordinary income. At a 37% marginal rate, that’s $370K in tax savings — often exceeding the investor’s out-of-pocket cash by a meaningful multiple.
✅ Active — Permanent
Section 168(k) provides 100% first-year bonus depreciation on qualified film production costs. Unlike Section 181, this applies to the actual production expenditures rather than the purchase price of an ownership interest.
The One Big Beautiful Bill Act (OBBBA) restored 100% bonus depreciation, making this structure fully active and available with no sunset provision.
An investor contributes $500K to a qualified film production. The full $500K is deductible as bonus depreciation in year one. At a 37% marginal rate, that’s $185K in tax savings.
✅ Active — No Legislative Risk
Through a Regulation D offering, production expenses are allocated and passed through to investor members of the production entity. The investor’s share of qualified production expenses flows through on Schedule K-1, creating deductions against ordinary income.
This structure requires no leverage — the investor’s cash contribution directly funds production expenses that generate the deduction. The potential deduction multiplier can reach approximately 4x the cash invested, depending on deal structure and expense allocation.
An investor contributes $250K cash. Their allocated share of production expenses totals $1M → $1M in pass-through deductions. At a 37% rate, that’s $370K in tax savings on a $250K cash investment — with no purchase money note required.
✅ Active — Collateral-Backed
Senior lending provides debt financing to film productions, secured against the film’s copyright and intellectual property. Loans are structured with conservative loan-to-value ratios — typically 85% against verified minimum guarantees (distribution pre-sales).
The investor holds a priority repayment position in the revenue waterfall. Returns are fixed and contractual, not dependent on the film’s box office or streaming performance exceeding projections.
A film has $1.2M in verified minimum guarantees from distribution pre-sales. The investor lends $1M (83% LTV) at 25% interest. The loan is repaid directly from distribution revenues before any profit participants. The film’s commercial success or failure doesn’t affect the security — the MGs are contractual obligations.
✅ Active — State-Secured
Tax credit lending provides loans to productions secured against state film tax credits. When a production qualifies for a state tax incentive (e.g., Illinois, Georgia, New Mexico), that credit becomes the collateral for the loan.
The key advantage: the film doesn’t need to succeed commercially for the investor to be repaid. State tax credits are obligations of the state government — they’re paid regardless of the film’s market performance.
A production qualifies for a $500K Illinois tax credit. The investor lends $450K (90% of credit value) at 15% interest. When the state issues the credit, the investor is repaid from those proceeds — independent of the film’s commercial outcome.
| Structure | Type | Returns | Risk Level | Tax Benefit | Status |
|---|---|---|---|---|---|
| Section 181 | Tax Equity | Varies + tax savings | Moderate | Full purchase price deduction | ⚠️ Expired (CREATES Act pending) |
| Section 168(k) | Tax Equity | Varies + tax savings | Moderate | 100% bonus depreciation | ✅ Active |
| Reg D Allocation | Tax Equity | Varies + tax savings | Moderate | ~4x expense pass-through | ✅ Active |
| Senior Lending | Secured Debt | 20–25% (negotiable) | Lower | None (yield-focused) | ✅ Active |
| Tax Credit Lending | Secured Debt | 10–20% (negotiable) | Lowest | None (yield-focused) | ✅ Active |
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