Equipment Lease Structures &
End-of-Term Options.
$1 buyout, FMV, 10% PUT, 10% option and TRAC, explained plainly. The one distinction that decides everything: a purchase option versus a purchase obligation.
iLease Capital structures financing for equipment purchases through funding partners, subject to equipment and credit review. When you finance equipment with a lease, the end-of-term structure can matter as much as the rate. The same machine on a $1 buyout, a fair market value lease, a 10 percent PUT, or a TRAC lease produces different payments, different flexibility, and a very different answer to a simple question: do you own the equipment at the end, and did you have a choice? This guide explains the common structures in plain language and sources the financial definitions. If you want to talk a specific structure through, a specialist is a call away at (866) 545-3273.
This is the reference companion to our program pages. For the loan-versus-lease decision on a specific machine, see our loan vs. lease framework, and to apply a particular structure, see our $1 buyout, FMV, and operating lease program pages.
The One Distinction That Matters Most: Option vs. Obligation
Before the acronyms, there is one question that organizes all of them. At the end of the term, are you allowed to buy the equipment, or are you required to? Those are two different things, and the difference changes what you are signing up for.
A purchase option is a right. Buying is elective; any return or renewal rights depend on the contract, including notice deadlines, condition requirements, and charges. A purchase obligation means the purchase is mandatory. The industry term for a mandatory purchase is a PUT, Purchase Upon Termination, which trade definitions describe as the requirement of a lessee to purchase equipment at a particular time and at a predetermined price. A fair market value purchase and a stated percentage purchase option are rights. A 10 percent PUT is a requirement. Keeping that straight is the single most useful thing a buyer can do when comparing lease quotes, because a lower monthly payment sometimes comes attached to an obligation to buy at the end.
$1 Buyout Lease
A $1 buyout provides a contractual option to acquire title for a nominal sum at term end after satisfying the agreement. The nominal purchase price generally supports an expectation that the option will be exercised, which is relevant to finance-lease accounting. It does not transfer legal title at inception. Compare the payment schedule, purchase requirements, and tax treatment with an equipment finance agreement rather than assuming the two contracts have identical terms.
Fair Market Value (FMV) Lease
An FMV purchase option sets the purchase price by the equipment’s fair market value at term end. That label alone does not establish operating-lease accounting. The contract may provide purchase, return, or renewal choices, subject to its notice deadlines, equipment-condition requirements, and charges. The allocation of residual risk and any guarantees depend on the agreement. Compare actual payments, return costs, renewal terms, and final obligations with a $1 buyout quote. The FMV lease tends to suit equipment a business expects to cycle out or upgrade, or technology that dates quickly, where a contractual return option may matter more than acquiring title. See our FMV lease program for the application path.
10 Percent Options, and the 10 Percent PUT
Ten percent structures sit between the $1 buyout and the FMV lease, and this is exactly where the option-versus-obligation distinction earns its keep, because two structures share the same number and behave very differently.
A 10 percent purchase option lets the lessee buy the equipment at term end for about 10 percent of its original cost, but the purchase is elective. Any return right remains subject to the contract, including notice, condition, and return costs. A 10 percent PUT, by contrast, is a Purchase Upon Termination, and the lessee is required to buy the equipment at that roughly 10 percent price. A required final purchase payment can reduce scheduled monthly payments compared with amortizing the same amount during the term, but pricing depends on the actual quote. The contractual obligation does not guarantee payment or resale value. A buyer comparing a 10 percent quote should confirm, in writing, whether it is an option or a PUT, because the monthly payments can look similar while the commitments are not.
TRAC and Split-TRAC Leases
A TRAC lease, for Terminal Rental Adjustment Clause, is a structure built for titled over-the-road vehicles, trucks, tractors, and trailers used primarily in the business. It is an open-end lease. The lessor and lessee agree on an estimated residual value at inception, and the terminal rental adjustment clause trues up the final payment against what the lessor actually realizes when the vehicle is sold at term end. The contract determines how sale proceeds, costs, and any shortfall or surplus affect the terminal adjustment. Under section 7701(h), a qualifying agreement is treated as a lease if it would be a lease without the terminal rental adjustment clause. The clause alone does not establish lease tax treatment.
A split-TRAC is a common variation in which the lessor absorbs part of the residual-value risk and the lessee's downside is capped at a stated maximum. If the end value falls short, the lessee pays only up to that cap instead of the full shortfall. The federal tax rule concerns qualifying motor vehicles, including trailers, which is why they come up in trucking and transportation financing rather than general equipment. For the equipment side of that market, see our trucking and transportation equipment financing guide.
Capital vs. Operating Lease, and Why Accounting Is Not Tax
Two different systems classify these structures, and they do not always agree, which is a frequent source of confusion. For financial accounting under ASC 842, a lease is a finance lease if it meets any one of several criteria, including that ownership transfers at term end, that there is a purchase option the lessee is reasonably certain to exercise, that the term covers the major part of the asset's remaining economic life, that the present value of lease payments plus applicable lessee residual-value guarantees represents substantially all of its fair value, or that the specialized asset is expected to have no alternative use to the lessor at term end. If none apply, it is an operating lease. Apply the full classification criteria with your accountant; a product name or buyout percentage alone does not decide the result.
Tax treatment is a separate question decided by the IRS, not by the accounting label. For federal income tax, the IRS looks at whether an arrangement is a true lease or, in substance, a conditional sale, based on the facts of the deal rather than what it is called. That determination drives who may claim depreciation and whether a structure supports Section 179. Because it is fact-specific, no article should state a tax outcome as automatic. Confirm depreciation, Section 179, and deduction questions with your own CPA. Our Section 179 guide works through the current-year figures, and your advisor can apply them to your situation.
Matching the Structure to the Equipment
The right structure follows from how you intend to use the equipment. A core asset you will run for a decade points toward ownership, a $1 buyout or an equipment finance agreement. Equipment you expect to upgrade in a few years, or technology that dates quickly, points toward an FMV lease so you keep the option to return it. Where reducing scheduled monthly payments is a priority and you are comfortable owning at the end, a 10 percent PUT can fit, as long as you recognize the mandatory purchase. Titled over-the-road vehicles have their own path through a TRAC or split-TRAC. The goal is to align the end-of-term outcome with the plan for the asset, rather than choosing on the monthly payment alone.
What to Confirm Before You Sign
Before signing, confirm whether the final purchase is optional or mandatory, how the buyout is calculated, and which notice deadlines, return conditions, renewal terms, and charges apply. For a TRAC or split-TRAC agreement, confirm the residual adjustment and any contractual cap. Compare the full payment schedule and final obligations, and ask your CPA about the tax treatment.
Frequently asked questions
What is the difference between a purchase option and a purchase obligation?
A purchase option is a right, not a requirement. At the end of the term you can choose to buy the equipment, but you do not have to. A purchase obligation means you are required to buy it. The clearest example of an obligation is a 10 percent PUT, or Purchase Upon Termination, where the lessee is required to purchase the equipment at a predetermined price. The clearest examples of options are a fair market value purchase and a stated 10 percent purchase option, where buying is elective. Always read the end-of-term section of the contract so you know which one you have.
Does a $1 buyout lease mean I own the equipment?
A $1 purchase option provides a contractual route to acquire title for a nominal amount at term end after satisfying the agreement. It does not mean you hold legal title from the start. A purchase option reasonably certain to be exercised is relevant to finance-lease classification, but accounting classification and legal ownership are different questions. Confirm the transfer requirements in the contract and discuss tax treatment with your CPA.
Is a 10 percent PUT the same as a 10 percent purchase option?
No, and the difference is important. A 10 percent PUT, or Purchase Upon Termination, is an obligation. You are required to purchase the equipment at the end of the term for about 10 percent of its original cost. A 10 percent purchase option is elective. The end price is similar, but any choice to buy or return is governed by the contract, including notice, condition, and charges. Deferring part of the purchase price to term end can reduce scheduled monthly payments, but compare actual quotes and the required final payment. The purchase obligation is not a guarantee that the lessee will pay.
What is a TRAC lease and who uses it?
A TRAC lease, which stands for Terminal Rental Adjustment Clause, is a structure for titled over-the-road vehicles such as trucks, tractors, and trailers used primarily in your business. The lessor and lessee agree on an estimated end-of-term residual at the start. When the vehicle is sold at term end, the final payment is adjusted up or down against what the lessor actually realizes. A split-TRAC is a variation where the lessor takes part of the residual risk and caps the lessee downside at an agreed maximum. Under section 7701(h), a qualifying agreement is treated as a lease if it would be a lease without the terminal rental adjustment clause. The clause alone does not establish lease tax treatment.
Which structure qualifies for Section 179?
As a general rule, the ownership-style structures, an equipment finance agreement and a $1 buyout, are the ones associated with Section 179, while a true fair market value lease generally is not because you do not own the asset. That said, tax treatment is decided by the facts of each deal and by the IRS distinction between a true lease and a conditional sale, not by the label on the contract. This is fact-specific, so confirm eligibility and the exact benefit with your own CPA or tax advisor rather than relying on a general rule. See our Section 179 guide for the current-year figures.
Can I change the end-of-term structure after I sign?
The end-of-term options are defined in the lease contract, so the time to choose a structure is before you sign, not after. Decide early whether you want ownership at term end, payment flexibility, or something in between, because that decision drives the payment and the documentation. A specialist can lay out the structures side by side for your specific equipment. You can start that conversation at (866) 545-3273.
At the end of a fair market value lease, what are my choices?
An FMV agreement may provide return, renewal, or purchase options. Confirm which choices your contract actually allows and what each requires. Because that purchase price is set at term end rather than fixed up front, it is not known precisely when you sign, and the contract governs how fair market value is determined, the notice you must give, and the condition the equipment must be returned in. If ownership is your goal, compare the full cost and obligations of the FMV purchase path with fixed-buyout or equipment-finance alternatives. Read the end-of-term section before you sign.
Not sure which structure fits your equipment?
Tell us the equipment and how long you plan to keep it. We will lay out the end-of-term options, option or obligation, and shop the structure across the network. No obligation.
(866) 545-3273Talk to a specialist who will explain the structure, not just the payment.
All financing subject to credit approval. Not a commitment to lend. Tax and accounting information in this article is general in nature, consult your CPA or tax advisor regarding your specific situation.