IRS wins another LILO case but slips up in arguing economic substance

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IRS wins another LILO case but slips up in arguing economic substance

Joe Dalton
August 07 2013
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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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Joe Dalton worked at ITR between 2011 and 2013
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