US life insurance company John Hancock has lost its Tax Court case concerning lease-in-lease-out (LILO) and sale-in-lease-out (SILO) transactions, meaning the Internal Revenue Service (IRS) continues its record of having won all cases on this issue. However, the IRS may have caused itself future difficulties by making an economic substance argument.
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India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist
ITR sat down for a pre-event interview with Tim Zech, WTS Germany, and Jeff Soar, WTS UK, keynote speaker at next week’s ITR AI in Tax Forum 2026 in London
India is signalling flexibility on expat taxation to attract foreign expertise, though employers will need to navigate disclosure, treaty and scope uncertainties