The US Tax Court has denied tax benefits from cross-border leasing transactions (John Hancock Life Insurance Company (USA), as Successor in Interest to John Hancock Life Insurance Company (f.k.a. John Hancock Mutual life Insurance Company) and Subsidiaries, et al. v. Commissioner of Internal Revenue, 141 T.C. No. 1, Docket Nos. 6404-09, 7083-10, 7084-10, 5 August 2013).
Facts
The case involved a US corporation that engaged in leveraged lease transactions (i.e. lease transactions in which …