[7th September 2000 – 10:00 AM, Gordon, Schmidt, & Van Dyke, World Trade Centre, Lower Manhattan]
The conference room on the sixty-ninth floor was quiet except for the soft hum of the air conditioning and the occasional rustle of paper. Floor-to-ceiling windows overlooked Lower Manhattan, the morning sun casting sharp lines across the polished mahogany table where three lawyers sat surrounded by enough documentation to build a small library.
Xavier James sat at the head of the table, dressed in a navy suit with no tie, his expression focused as he reviewed a spreadsheet on his laptop. To his right sat Jess Person, impeccably dressed as always, her reading glasses perched on her nose as she made notes in the margins of a thick legal brief. Harvey Specter occupied the seat beside her, his burgundy tie loosened slightly, sleeves rolled to his elbows as he flipped through a binder marked PERMITS & APPROVALS.
Across from them sat David Fisher, a man in his mid-thirties with sharp features and confidence that came from being an ACE closer. He was a Junior partner at his family's firm, Chace and Fisher, specialised in the kind of corporate architecture that kept billionaires out of courtrooms and the IRS off their doorsteps. They were one of the four knights of financial law in New York, their services sought after by every rich person in the city.
"Alright," Xavier said, closing his laptop and folding his hands on the table. "Let's start with the good news. Demolition's done?"
"Finished ahead of schedule," Harvey confirmed, not looking up from his binder. "Both sites—College Point and Creedmoor—are cleared, surveyed, and ready for groundbreaking. Samsung C&T and Hyundai E&C are finalising their logistics teams. October fourteenth is locked in."
"Environmental remediation?" Xavier asked.
"Completed on the waterfront parcels," Jess said. "Phase III testing came back clean last week. The EPA signed off on everything. No outstanding issues."
Xavier nodded slowly. "And the permits?"
Jess pulled a thick folder from the stack in front of her and slid it across the table. "Everything you need is in here. Building permits, zoning approvals, commencement certificates, utility hookups, traffic impact assessments—every box checked, every signature secured."
Harvey leaned back, crossing his arms. "I'll spare you the legal jargon, but the short version is this: You're clear to build. No regulatory roadblocks, no neighbourhood associations with standing to sue, no surprise injunctions from Mara's lawyers. We locked it down tight."
"And insurance?" Xavier asked.
"Comprehensive," Harvey said with a weird expression. "On-site death and injury, property damage, environmental liability, construction delays, terrorism, natural disasters—we've covered everything short of alien invasion."
"Don't joke about that," Harvey said dryly. "I've seen policies for weirder things."
Xavier smiled faintly. "Alright. So we're legally bulletproof. What about the business structure?"
David Fisher, who had been quietly reviewing his own notes, finally spoke. His voice was calm, measured, and a little proud as he presented his work, ready to receive praise that would never see the light of a courtroom. "That's where it gets interesting."
He pulled out a large diagram, a flowchart showing the corporate structure of his sporting business. "Let me walk you through this."
Xavier leaned forward, eyes locked on the chart. "First," David said, tapping the top of the diagram, "we've established Rex Holdings in the Netherlands. This is your master entity—the top of the pyramid. It owns everything downstream and provides three critical benefits: tax efficiency, asset protection, and opacity. The NFL, the IRS, and the media can't easily trace ownership back to you personally."
"How legal is that?" Xavier asked about having done a similar structure for investment firms on Wall Street. When it came to how you invest in certain markets to pay the least amount in taxes, none was as good as firms on Wall Street. He had done something similar for his Apex venture holdings, setting up different offshore accounts firms to pay the least amount of taxes possible.
"Completely," David said without hesitation. "Dutch holding companies are a standard structure for international asset management. As long as you file the proper disclosures and maintain clean accounting, there's nothing objectionable about it."
Harvey smirked. "Translation: It's legal, but it'll piss off anyone who looks at it closely."
"Which is why," David continued smoothly, "we've layered it correctly. Rex Holdings owns two Delaware LLCs beneath it."
He tapped the next level of the chart. "Tekton Development Holdings LLC—this entity owns one hundred per cent of the land, the stadium, the plazas, the parking structures, and all retail space. It's a real estate company, not a football company. That distinction is critical."
"Why is that?" Xavier asked, genuinely curious.
"Because," David said, "when the NFL or the league's finance committee looks at your franchise valuation, they'll see the Tigers as a football operation with standard revenue streams—ticket sales, sponsorships, merchandise. But the stadium itself? That's a separate asset owned by a separate entity. It keeps your franchise valuation lower, which matters for league assessments, revenue sharing calculations, and potential future sales."
`Xavier nodded slowly. "And the second LLC is the franchise?"
"Correct New York Tigers Football Holdings LLC," David said, pointing to the parallel box on the chart. "This is your football operation. It owns the NFL franchise, holds the league membership, pays players and coaches, and receives all football-related revenue—NFL national revenue, ticket sales net of stadium rent, and team-specific sponsorships. One hundred per cent owned by you through Rex Holdings."
"And the two entities interact how?" Xavier asked.
David pulled out another document—a detailed profit-sharing agreement. "This is where we get clever. The holding company and the football operation have a contractual relationship that splits revenues based on what's being generated."
He read from the document: "Non-NFL events—concerts, festivals, shows—gross profit split after operating costs is seventy-five per cent to the holding company, twenty-five per cent to the Tigers."
"Not that it matters much to me, but why not fifty-fifty?" Xavier asked.
"Because," David explained, "the holding company is taking on the capital risk of building and maintaining the stadium. It's fronting the construction costs, the ongoing maintenance, and the upgrades. The Tigers benefit from having a world-class venue without carrying that financial burden directly. Plus, it has to pay a $2 billion loan from James Holding, which took out the initial loan from Bank of America."
Xavier smiled when that loan was mentioned, as he had managed to chop it down to 1.6 in the past month. The privately resold debt that the bank had put in the market had initially been snapped up quickly, but upon the crash, it became waste paper. Many investment firms which had gone under had been the ones to buy his debt at premiums, but upon facing bankruptcy, he bout it back for pennies.
Still, the debt that Tekton had to pay remained at $2 billion, allowing them to operate at a deficit for a few years. Harvey jumped in. "It also creates a firewall. If the football team ever faces financial trouble—lawsuits, league penalties, whatever—the stadium itself is protected because a separate entity owns it. Vice vercer."
David continued. "Retail, food courts, bars, fan zones—anything generating year-round income—that's eighty per cent holding company, twenty per cent Tigers. This is treated as real estate income, not football revenue."
"Parking?" Xavier asked.
"Seventy per cent holding company, thirty per cent Tigers," David said. "Helps cover match-day operating costs without inflating the team's valuation."
"And naming rights?"
"One hundred per cent with the holding company," David confirmed. "That preserves flexibility for financing, sponsorship strategy, and future renegotiation. If you want to sell naming rights for two hundred million over ten years, that revenue goes to Tekton Development Holdings, not the Tigers."
Xavier sat back, processing. "So the Tigers still pay rent to the holding company?"
"Correct," David said. "Sixteen million annually, with a two to two-point-five per cent escalation clause tied to inflation. Ten-year term with options to extend."
"That seems... high," Xavier said carefully.
"It's market rate for a stadium that is set to be the biggest in the league, both in capacity and technology," Jess said. "And it has to be. If you charge the Tigers below-market rent, the IRS could flag it as a gift or a related-party transaction designed to hide income. We need everything arm's length."
"Plus," Harvey added, "the rent creates a paper trail that shows the holding company is a legitimate business entity, not just a tax shelter."
David flipped to the next page. "Non-NFL sports usage—college games, international soccer matches, exhibitions, Olympics—stays one hundred per cent with the holding company. Not shared."
"But the Tigers get priority scheduling," Jess clarified. "Contractually, the stadium is always available for football first. No conflicts, no blackout dates. Brand dominance is protected—the stadium is always visually and commercially 'The House of the Tigers.'"
Xavier studied the documents for a long moment. "And the Tigers' profit share from all this—what's it earmarked for?"
"Non-playing purposes," David said. "Fan experience, community projects, stadium technology, facility upgrades. It can't be used to make the franchise more attractive to free agents by showing them world-class facilities."
Jess added, "And because Rex Holdings is based in the Netherlands, there's an additional layer of privacy. No one can easily trace the ownership structure back to you without going through international legal channels."
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To Be Continued...