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.
The latest edition of Taxing Times with ITR covers all the controversy from a dramatic period for the carve-out deal, and also dissects the big four's AI strategies
Hany Elnaggar examines how the OECD’s global minimum tax is reshaping PE concepts across the GCC, shifting the focus from formal presence to substantive economic activity
Following Richard Houston’s switch to the newly formed Deloitte EMEA, Graves has the opportunity to bring Deloitte’s tax practice up to speed with its rivals