A “silo” might be a farm building, but in the equipment leasing industry it means a “sale-in, lease-out” transaction. While considered fairly routine in most quarters, in recent years the Internal Revenue Service has flagged such deals as potentially abusive tax shelters.
Deals At Risk: Textron Opens Door to IRS Discovery of 'Tax Accrual Workpapers'
SILOs underlie a confrontation between a taxpayer and the IRS in the new First Circuit case of <i>United States v. Textron Inc.</i> But that decision was not just about the legality or taxing of such leases. Rather, it has grave consequences on a far more sweeping issue: the inability of taxpayers to shield from disclosure so-called "tax accrual workpapers," documents typically prepared by in-house tax attorneys that set out in detail sensitive areas of tax liability.
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Anthony M. SabinoThis premium content is locked for LawJournalNewsletters subscribers only
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