When an owner contemplates the sale of a very-high-value asset, usually he or she plans to re-invest the sale proceeds, rather than spend them in riotous living. Also, the owner's objective is not so much to receive the principal sum, but instead to achieve an attractive long-term income (possibly with tax advantages) which reflects the productive value of the entire investment.

Moreover, the owner typically wants to put into place a plan for the ultimate disposition of the proceeds and income that enables accomplishment of personal, family and sometimes charitable objectives, preferably at minimized tax cost.

In a "perpetual" C453 ("PC453") transaction, S.Crow Collateral Corp. is the intermediate buyer of the asset and as such can achieve results which, as far as we know, no one else can. The PC453 transaction is not itself the owner's estate plan—advising about estate plans is not our business—but it can implement an owner's estate plan with unique effectiveness.