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Home / Opinion Digests / Taxation – LILO Transaction – No Genuine Debt (access required)

Taxation – LILO Transaction – No Genuine Debt (access required)

A district court did not err in ruling that this “lease-in, lease-out” transaction did not allow the taxpayer to acquire a genuine leasehold interest or incur a genuine debt, and the 4th Circuit upholds the IRS’s disallowance of the deductions the taxpayer claimed for its LILO transaction. This appeal requires us to determine the tax consequences ...