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

Joe Dalton

August 07 2013

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.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Request Access or Login

Topics

News Tax Disputes United States (National)

Joe Dalton

Joe Dalton worked at ITR between 2011 and 2013

more across site & shared bottom lb ros

More from across our site

Direct Tax

KPMG confirms settlement with whistleblower who alleged tax division wrongdoing

Historical claims involving KPMG Australia's tax practice have surfaced as the firm battles a separate parliamentary inquiry into its handling of whistleblowers

Sam Sholli, August 14 2026

Direct Tax

Humanoid head with screens of graphs in the background

A taxing week: Democratised insights, inflated rates – the widening value gap in tax advisory

While AI is revolutionising tax work, it is also reshaping clients’ willingness to pay for advice and their perception of the value generated by tax advisers

Jorge Gallardo, August 14 2026

Podcasts

Podcast: Ryan's Tom Shave on acquisitions, competition and PE

From Dhruva Advisors to Svalner Atlas, Ryan is growing fast. Tom Shave discusses consolidation, competition, and tax’s private equity debate

Tom Baker, August 13 2026

Awards

ITR Middle East Tax Awards 2026: shortlist announced

ITR is delighted to reveal the shortlisted nominees for the Middle East Tax Awards

John Harrison, August 13 2026

Direct Tax

Unpacking HMRC’s approach to the pillar two side-by-side package

The UK has confirmed its approach to the OECD’s side-by-side deal, but US-parented groups may find pillar two compliance remains far from straightforward

Lauren Smyth, August 12 2026

Direct Tax

Multinationals brace for more tax disputes: Baker McKenzie survey

Fragmented pillar two taxation and increased use of AI by tax authorities have left clients fearful of heightened disputes exposure

Antonia Maria Azpeitia , August 11 2026

Direct Tax

Beyond the headlines: Why Grant Thornton’s CBIZ deal won’t create a ‘big five’

Grant Thornton Advisors’ latest acquisition has produced the fifth-largest US advisory firm by revenue, but there’s still a clear gulf between it and the big four

Tom Baker, August 10 2026

Direct Tax

Crowe secures private equity investment from KKR

Crowe joins Grant Thornton, WTS and Ryan in attracting PE investment, suggesting that dealmakers remain bullish on the tax advisory sector

Sam Sholli, August 10 2026

Direct Tax

A taxing week: HMRC's audit woes will rightly fuel tax adviser concerns

HMRC expects advisers to meet ever-higher compliance criteria. After 24 consecutive qualified audit opinions, many will ask whether HMRC should hold itself to the same standards

Sam Sholli, August 07 2026

Indirect Tax

Wolters Kluwer acquires tax automation provider for €112m

The purchase of Marosa represents the second major tax tech consolidation this week, raising questions of a broader industry trend

Sam Sholli, August 06 2026