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Prior to COVID-19, the market comprised too many capital providers chasing too few good deals, a scenario CIT Group’s Chris Niederpruem considered “the new normal…I don’t know what changes that.”
Nobody foresaw what would unfold a little more than a month after Commercial Observer met with Niederpruem in CIT’s offices at 11 West 42nd Street in January.
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It’s not often you experience a near-apocalyptic event that causes a public health and economic crisis within your first full year of taking over a multibillion-dollar institutional real estate banking practice.
But Niederpruem, 45, was stoic when CO caught up with him a few weeks ago. CIT is first and foremost a relationship real estate lender — and don’t call that a cliché. For nearly nine years since Niederpruem was part of a six-person group that was hired by CIT to kick-start its real estate finance business from scratch, this is how it has differentiated itself, providing a single touch point for its borrowers. Repeat business comprises around half of its activity across the country.
Last year, in an overcrowded market, CIT originated $3.3 billion on its balance sheet, up from $2.9 billion in 2018 and a nearly 47 percent climb since 2016.
CIT has made a name for itself providing construction debt and senior secured loans on value-add opportunities, something Niederpruem previously said has become more difficult in recent years due to the proliferation of finance companies in the space.
But in the last two years, it’s tried to carve a way around that by originating whole loans while selling off the subordinate debt in favor of retaining the senior position, where it has historically lived.
The $163 million debt package CITand BlackRockoriginated in March to fund The Arden Group’s acquisition of a 2.1 million-square-foot, 12-property U.S. industrial portfolio is evidence of this strategy — CIT booked a $134.3 million senior portion.
Born into a military family, Niederpruem moved around a lot growing up, living in around a half-dozen locations prior to starting high school; his dad was an attorney serving in the JAG Corps. (Niederpruem has spent the last 20 years in New York, and his wife and four kids are here to stay, he said.) When he was about 8 years old in the early 1980s, his family lived in Seoul, South Korea for about two years during what was a very turbulent time on the Korean peninsula
Beyond that, his family moved around the East Coast and Mid-Atlantic regions, eventually settling in upstate New York, where he spent his high school and college years in Syracuse.
He moved to New York in 1999, after he received his English degree from Le Moyne College, for a two-year stint to “see what it was all about,” he said. He eventually joined a boutique real estate mortgage brokerage shop in the city and then was hired by Dublin, Ireland-based KBC Bank in 2005. After a second stint at another Irish bank, he joined Bank of Ireland in 2008, where he’d meet CIT Group’s former head of real estate finance, Matt Galligan, from whom he took over last year.
Commercial Observer: How did you make your way into real estate finance?
Chris Niederpruem: I found my way into real estate through a college classmate, whose family was in the real estate business. He made an introduction for me, and I got into the business on the mortgage brokerage side. I did that for a small boutique mortgage brokerage in New York, spending a lot of time around the outer boroughs. After a few years of that, I fell in love with commercial real estate. It’s a touch-it-feel-it fixed asset, which is interesting. And other things, like the architecture and the design are interesting as well. It’s a good way to be both in and out of the office. There’s the financial piece of it in the office and then you get out and about and spend time with customers and see the real estate. That’s why I fell in love with it. I’m somewhat conservative by nature, so I wanted to not be in a role where I was dependent on a fee business. So I found my way into banking after a couple of years on the brokerage side.
Talk about that transition, with Matt Galligan, from Bank of Ireland to CIT right after the crisis.
During 2008, my wife worked in financial services. So, the two of us are staring at each other going, “Okay, which one of us is going to lose our job first?” Neither of us [did]. I was close with the Bank of Ireland, and we eventually were selling our loan book, so I was either going to [go to CIT] or be out of work. So, 2011 was an interesting year; we sold our way out of a job as we sold the loan portfolio at the Bank of Ireland. Closed on Friday, joined CIT on a Monday, and three weeks later, my first son was born. It was an interesting month, to say the least. I was sweating a little bit those days.
We met the management team here at CIT through that [sale] process, and they hired us. We were fortunate enough that [Bank of Ireland] allowed us to be part of the sale process, so we were able to meet with some of the more interested groups that were looking at the loan portfolio. When the loan book bid process was over, they said, “Well, we’d still like to bring you on.” They said they wanted to restart their commercial real estate platform that they previously had. So we started here in 2011.
What was it like at the beginning, essentially starting from scratch with no legacy book?
We arrived, wrote a business plan, which we had obviously vetted in advance. And we really started lending in January 2012.
Wow, very quick.
Yes, very quick. We started on October 3, 2011, and before the year was out in December, we closed our first transaction. So we were still finalizing a business plan, and we had already executed on a transaction for a client that we knew and was counting on us for financing, and we were able to deliver very quickly.
How has CIT’s product offerings expanded in the last several years?
The core of our business remains. We’re a value-add and construction lender. In the last [couple years] the market [became] probably the most competitive it’s been since I’ve been in the business. There’s so much capital both on the debt and the equity side, but primarily on the debt side, so you have to try to do some things a little bit differently than everybody else. We’ve stayed the course for the most part. What we’ve done to try to compete with that [debt fund] segment of the market, because they tend to be right in our space of value-add lending, we will also provide a mezzanine product. [We’ll] arrange both a senior loan and a mezzanine loan, which is really where they compete. They’ll originate that loan, and they’ll sell the most senior piece. We’re doing the converse, originating that entire stack and selling the riskier piece out to them. We’ve found some success in doing that. And also, our clients like that it’s a single point of contact [with us]. We’ll originate your loan, lead the negotiation of the documentation and continue to manage that. We’ve found that clients put a lot of value on that, especially after the last cycle. It’s not a huge piece of [our book].It’s just another kind of tool in the tool belt so to speak. Our biggest value add to our customers is that we are a single point of contact, and we’re able to be a little more nimble, a little more flexible. Our speed and certainty of execution is really what we deliver to folks. The larger the organization, the more red tape you have. We have a very flat organization, so to get a decision made here is pretty quick.
What’s the breakdown of your portfolio by asset class?
The three largest in terms of just directionally is multifamily, office and then industrial are the biggest three in our portfolio.
Tell us a bit about your relationship with Matt Galligan.
He’s certainly been a mentor to me at times since we’ve worked together. I feel like I’ve been through more economic cycles than I have just by spending the time working with Matt. He’s been through a couple more than I have, and there’s a lot of value in that. I’ve learned as much about working in a large organization from Matt as I have about the real estate business, candidly.
He’s spent his career in banking in various large organizations. He started his career at Chase, and he worked at FleetBoston. There is a skill to working in large organizations and navigating the bureaucracy and the politics, and I’ve learned some of that from him. In terms of real estate, I’ve learned about the importance of who you’re lending money to. We talk a lot about sponsorship around here. Do they have the experience, the integrity, the wherewithal to weather a downturn? Or not even a downturn but just a bump in that particular investment or that particular project. At any point, wherever you might be in an economic cycle, that’s terribly important. Matt has said it to lots of us over the years: You want to make sure you’re dealing with good people. Keep it simple. Deal with good people, and you’ll end up with a good outcome.
As a passing of the baton type of scenario, how’s the transition to the new role gone?
It’s an interesting dynamic that we’ve gone through. It’s a phenomenal opportunity for me to take over this business. Life is about timing. I can’t say that when I started 2019 that I thought this was the year that we would pass the torch. He continues to be a champion of mine. He has graciously allowed me to quickly take over running the business. In a lot of places, Matt would retire, and we’d give him his gold watch and send them off, right? Here, he’s around for a bit longer in a new role. He provides me guidance and support when I need it. He will tell you he stays out of my way as much as he can.
What’s something you want to bring to CIT?
One of the things that we started doing in 2019 — and I think we’ll continue to do more of it through the next few years — is elevate the profile of CIT as the lead bank. In the early days in our business, [we’d] partner with other lenders and come in as a participant in other banks’ deals. We’ve slowly transitioned the business to be more of a sole lender. We’ll continue to [try] to take the lead in larger transactions. It provides a broader solution to our customers.
Given CIT’s investment strategy, how has the business been impacted by COVID-19?
We’ve really focused on experienced investors and developers that have the financial wherewithal to weather any economic cycle. We’ve continued to do that through 2019 and up until this point. Because of that, it hasn’t caused us to really change our strategy; it’s tried and true what we’ve built. [And that remains true] even through these uncertain and unusual times.
We are still open for business. We’re still looking at new opportunities. It’s an uncertain time not just for commercial real estate but the economy in general. There will be changes to the different sectors of commercial real estate, so like anyone else who’s an investor or lender in the space, we’re cautiously diligencing any opportunities that we pursue based on changes that have or may come on the back of the pandemic.
How would you describe your experiences with the Great Financial Crisis, versus now?
People say the only thing similar about these events is they’re all different, and that certainly holds true with COVID-19, versus the Financial Crisis a decade ago. This is really broad, sweeping, and it’s first and foremost a public health crisis that’s had financial impact.
We’ve continued to stay the course and try to support both our existing clients and new prospects that fit our strategy. The last several years have been very active in the CRE sector, in investment sales and development. It’s continued but not to the level it has in the past. The marketplace is certainly shifting. It’s a terribly fluid situation. We’ll focus on major markets nationally. The acquisition market doesn’t seem to be completely gone. There are transactions happening. People are still raising money — debt and equity funds are still being raised and deployed, and developers are breaking ground on new projects.
[email protected] Irland CIT Group Finance (Ireland) CIT House Blackrock Business Park Carysfort Avenue Dublin Irland Tel.: +353 (0) 1 279 6271
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[email protected] Irland CIT Group Finance (Ireland) CIT House Blackrock Business Park Carysfort Avenue Dublin Irland. Tel.: +353 (0) 1 279 6271
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Amazon had sales income of €44bn in Europe in 2020 but paid no corporation tax
Fresh questions have been raised over Amazon’s tax planning after its latest corporate filings in Luxembourg revealed that the company collected record sales income of €44bn (£38bn) in Europe last year but did not have to pay any corporation tax to the Grand Duchy.
Accounts for Amazon EU Sarl, through which it sells products to hundreds of millions of households in the UK and across Europe, show that despite collecting record income, the Luxembourg unit made a €1.2bn loss and therefore paid no tax.
In fact the unit was granted €56m in tax credits it can use to offset any future tax bills should it turn a profit. The company has €2.7bn worth of carried forward losses stored up, which can be used against any tax payable on future profits.
The Luxembourg unit – which handles sales for the UK, France, Germany, Italy, the Netherlands, Poland, Spain and Sweden – employs just 5,262 staff meaning that the income per employ amounts to €8.4m.
Margaret Hodge, a Labour MP who has long campaigned against tax avoidance, said: “It seems that Amazon’s relentless campaign of appalling tax avoidance continues.
“Amazon’s revenues have soared under the pandemic while our high streets struggle, yet it continues to shift its profits to tax havens like Luxembourg to avoid paying its fair share of tax. These big digital companies all rely on our public services, our infrastructure, and our educated and healthy workforce. But unlike smaller businesses and hard-working taxpayers, the tech giants fail to pay fairly into the common pot for the common good.
“President Biden has proposed a new, fairer system for taxing large corporations and digital companies but the UK has not come out in support of the reforms. The silence is deafening. The government must act and help to grasp this once-in-a-generation opportunity to banish corporate tax avoidance to a thing of the past.”
Paul Monaghan, the chief executive of the Fair Tax Foundation, said: “These figures are mind-blowing, even for Amazon. We are seeing exponentially accelerated market domination across the globe on the back of income that continues to be largely untaxed – allowing it to unfairly undercut local businesses that take a more responsible approach.
“The bulk of Amazon’s UK income is booked offshore, in the enormously loss-making Luxembourg subsidiary, which means that not only are they not making a meaningful tax contribution now, but are unlikely to do so for years to come given the enormous carried forward losses they have now built up there.”
The Amazon EU Sarl accounts filed in Luxembourg show 2020 sales rose by €12bn from €32bn in 2019. The accounts, that extend to just 23 pages (compared with hundreds of pages for large UK companies), do not break down how much money Amazon made from sales in each European country.
However, Amazon’s US accounts show that its UK income soared by 51% last year to a record $26.5bn (£19.4bn) as people at home during the coronavirus pandemic lockdowns turned to it for online shopping as high street stores remained closed for most of the year, while homeworking drove increased use of its cloud software, Amazon Web Services.
While Amazon celebrated the rise in revenue collected from UK customers, it did not state how much corporation tax it paid in the UK in total last year. The company, which has made its founder and outgoing chief executive Jeff Bezos a $200bn fortune, paid just £293m in tax in 2019 despite the company collecting UK sales of $17.5bn that year.
The £19.5bn that UK customers spent at Amazon in 2020 is approximately double the takings at Marks & Spencer, the 137-year-old retailer, and underlines how the Covid-19 pandemic is revolutionising the way we shop and threatening the future of the high street. Last week Amazon reported its largest ever quarterly profit of $8.1bn on sales of $109bn.
An Amazon spokesperson said: “Amazon pays all the taxes required in every country where we operate. Corporate tax is based on profits, not revenues, and our profits have remained low given our heavy investments and the fact that retail is a highly competitive, low margin business.
“We’ve invested well over €78bn in Europe since 2010, and much of that investment is in infrastructure that creates many thousands of new jobs, generates significant local tax revenue, and supports small European firms.”
Doug Gurr, the recently-departed managing director of Amazon.co.uk, has explained that: “The Amazon.co.uk website is operated by Amazon EU Sarl, a Luxembourg-based entity, which is a European headquarters of Amazon.”
Just over 600,000 people live in Luxembourg but many of the world’s biggest companies have headquarters in the low-tax country.
Amazon arrived in Luxembourg in 2003, and within a few months secured a confidential agreement with the country’s tax authorities.
Bob Comfort, Amazon’s head of tax until 2011, told a Luxembourg newspaper that Jean-Claude Juncker – then the country’s prime minister and a former president of the European Commission – had personally offered to help Amazon.
“His message was simply: ‘If you encounter problems which you don’t seem to be able to resolve, please come back and tell me. I’ll try to help.’” Comfort was later appointed Luxembourg’s honorary consul to Seattle, the location of Amazon’s US headquarters.
Last month Joe Biden tabled plans at the Organisation for Economic Co-operation and Development, a club of mostly rich countries, for sweeping changes to the global tax system, including a minimum corporation tax rate in an attempt to stop multinational companies exploiting loopholes in the system. Germany and France have backed the plans but the UK has remained silent.
Washington had long resisted calls for the global treaties that reformers argued were needed to ensure that powerful multinational companies pay their fair share of taxes.
Under the US president’s proposals, large technology companies and corporations would be forced to pay taxes to national governments based on the sales they generate in each country, irrespective of where they are based.
A global tax floor would also be agreed. The US has suggested a rate of 21%, although this is higher than in several jurisdictions – including Ireland, Hungary and the Caribbean – and could be a stumbling block.
Bezos, the world’s richest person, welcomed Biden’s proposals and said Amazon was “supportive of a rise in the corporate tax rate”.
Amazon is not alone in creating complex corporate structures to avoid tax. The big six US tech firms – Amazon, Facebook, Google, Netflix, Apple and Microsoft – have been accused of avoiding $100bn of global tax over the past decade, according to a report by the campaign group the Fair Tax Foundation. All have said that they pay the correct amounts of tax.
The report singles out Amazon as the worst offender. It said the group paid just $3.4bn (£2.6bn) in tax on its income so far this decade, despite achieving revenues of $961bn and profits of $26.8bn.
The Fair Tax Foundation said this meant Amazon’s effective tax rate was 12.7% over the decade when the headline tax rate in the US had been 35% for most of that period.
Amazon said the report’s “suggestions are wrong” and the company had “a 24% effective tax rate on profits from 2010-18”.
There's still no Jack Grealish or Phil Foden in today's Manchester City squad.
Gabriel Jesus is rewarded for his winner against Paris St-Germain on Wednesday with a start. Aymeric Laporte replaces John Stones in the only other change from that Champions League win.
Pep Guardiola has only named eight, rather than nine, subs.
Man City XI: Ederson, Walker, Dias, Laporte, Cancelo, Rodri, Gundogan, Bernardo, Sterling, Jesus, Mahrez.
Subs: Steffen (GK), Carson (GK), Stones, Ake, Zinchenko, Fernandinho, Palmer, McAtee.
West Ham make just the one change from their last Premier League game. Jarrod Bowen drops to the bench and is replaced by Arthur Masuaku.
West Ham XI: Fabianski, Johnson, Dawson, Zouma, Creswell, Soucek, Rice, Masuaku, Benrahma, Fornals, Antonio.
Subs: Areola (GK), Coufal, Yarmolenko, Lanzini, Vlasic, Noble, Bowen, Diop, Kral.
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