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 equity investors finance the acquisition of an asset partly with borrowings and lease the asset to its ultimate user). The leveraged lease transactions included three lease-in-lease-out...