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In the Marketplace
The Equipment Leasing and Finance Association ('ELFA') has filed two separate amicus curiae briefs regarding the use of deductions generated through participation in Lease-In/Lease-Out ('LILO') transactions. In both briefs, the ELFA argues that the correct tax treatment of leaseback transactions ' and commercial leasing transactions in general ' are cast into doubt.
In the first case, the ELFA filed a motion and amicus brief before the Fourth Circuit in support of the appellant, BB&T Corporation, in its appeal of the decision of the U.S. District Court for the Middle District of North Carolina in BBT Corporation v. USA, No. 1:04-cv-00941-NCT (Jan. 4, 2007). The transaction involved the lease and sublease of pulp manufacturing equipment. The plaintiff, BB&T Corporation, had certain tax deductions disallowed by the Internal Revenue Service in connection with BB&T's participation in a LILO transaction with Sodra Cell AB, a Swedish company. As described by the court, the deal consisted of a 'Head Lease' in which BB&T acquired an undivided interest in the equipment for a period of 36 years and an immediate shorter term sublease of the undivided interest in the equipment back to Sodra for a term of 15.5 years.
Why So Many Great Lawyers Stink at Business Development and What Law Firms Are Doing About It
Why is it that those who are best skilled at advocating for others are ill-equipped at advocating for their own skills and what to do about it?
Bankruptcy Sales: Finding a Diamond In the Rough
There is no efficient market for the sale of bankruptcy assets. Inefficient markets yield a transactional drag, potentially dampening the ability of debtors and trustees to maximize value for creditors. This article identifies ways in which investors may more easily discover bankruptcy asset sales.
The DOJ's Corporate Enforcement Policy: One Year Later
The DOJ's Criminal Division issued three declinations since the issuance of the revised CEP a year ago. Review of these cases gives insight into DOJ's implementation of the new policy in practice.
A Lawyer's System for Active Reading
Active reading comprises many daily tasks lawyers engage in, including highlighting, annotating, note taking, comparing and searching texts. It demands more than flipping or turning pages.
Blockchain Domains: New Developments for Brand Owners
Blockchain domain names offer decentralized alternatives to traditional DNS-based domain names, promising enhanced security, privacy and censorship resistance. However, these benefits come with significant challenges, particularly for brand owners seeking to protect their trademarks in these new digital spaces.