Alston & Bird Tax Blog

Federal Tax Advisory: Better Luck with Economic Substance Doctrine: John Hancock Life Insurance Co. v. Commissioner, 141 T.C. No. 1 (2013)

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This advisory discusses a recent U.S. Tax Court ruling on a combination of LILO and SILO transactions that were supposed to generate lease and depreciation deductions. The IRS attacked the deductions primarily under what it called the substance-over-form doctrine, and secondarily under the economic substance doctrine. The taxpayer won the economic substance doctrine issue, but lost the substance-over-form issue. There are several lessons here for taxpayers.

The full advisory is provided on the Alston & Bird website: http://www.alston.com/advisories/fed-tax-sept-2013/

Written by Jack Cummings, Partner, Tax | Alston & Bird LLP

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About Jasper L. (Jack) Cummings, Jr.

Jack Cummings is counsel in the Federal Tax Group of Alston & Bird in Raleigh and Washington, D.C. He served as IRS associate chief counsel (corporate) and chair of the Corporate Tax Committee of the ABA Section of Taxation.

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About Edward Tanenbaum

Edward Tanenbaum is co-chair of the firm’s Federal & International Tax Group and a member of the firm’s Global Resources & Strategies Committee. Mr. Tanenbaum’s practice consists primarily of planning and structuring tax efficient solutions for cross-border business transactions and investments by foreign multinational corporations and high-net-worth individuals.

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