UNITED STATES TAX COURT
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141 T.C. No. 1
UNITED STATES TAX COURT
JOHN HANCOCK LIFE INSURANCE COMPANY (U.S.A.), AS SUCCESSOR
IN INTEREST TO JOHN HANCOCK LIFE INSURANCE COMPANY (f.k.a.
JOHN HANCOCK MUTUAL LIFE INSURANCE COMPANY) AND
SUBSIDIARIES, ET AL.,' Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 6404-09, 7083-10,
7084-10.
Filed August 5, 2013.
JH is primarily in the business of selling life insurance policies,
annuities, long-term care insurance, and other retirement services. To
fulfill its contractual obligations under these services JH invests the
premiums it receives. In 1979 JH began investing in leveraged
leases. A leveraged lease is a lease in which the equity investor
iCases of the following petitioners are consolidated herewith: The
Manufacturers Investment Corporation and Subsidiaries, as successor in interest to
John Hancock Financial Services, Inc., and Subsidiaries, docket No. 7083-10; and
John Hancock Life Insurance Company (U.S.A.) and Subsidiaries, as successor in
interest to John Hancock Life Insurance Company (f.k.a. John Hancock Mutual
Life), docket No. 7084-10.
SERVED Aug 05 2013
-2borrows money from a third-party lender to finance a portion of the
purchase price of the asset involved and leases the asset to its ultimate
user.
In 1997 JH began investing in lease-in-lease-out (LILO)
transactions and in 1999 began investing in sale-in-lease-out (SILO)
transactions. JH participated in 19 LILO transactions and 8 SILO
transactions between 1997 and 2001.
With respect to the LILO transactions, JH claimed deductions
for rental expenses for the prepaid rent paid to the tax-indifferent
entities and interest expenses related to the repayment of the
nonrecourse loans. JH also amortized transaction costs related to the
LILO transactions. With respect to the SILO transactions, JH
claimed deductions for depreciation and interest expenses and
amortized the related transaction costs. R disallowed these
deductions for the years at issue and determined that JH had OID
income with respect to the LILO and SILO transactions.
The parties agreed to litigate three LILO transactions and four
SILO transactions and use them as test transactions for the remaining
LILO and SILO transactions at issue.
A transaction will be respected for Federal income tax purposes
if it has economic substance and the substance of the transaction is
consistent with its form. P argues that the LILO and SILO test
transactions have economic substance because JH derived a pretax
profit from each transaction and entered into the transactions with the
primary purpose of making a profit. P also argues that the substance
of each LILO and SILO transaction is consistent with its form
because JH held a true leasehold interest in each of the LILO assets
and obtained an ownership interest in each of the SILO assets. R
argues that the LILO and SILO test transactions lack economic
substance and the substance of the transactions is not consistent with
their form. Specifically, R argues that JH failed to acquire a
substantive leasehold interest in the LILO assets and failed to acquire
a substantive ownership interest in the SILO assets. Thus, R argues
-3the true substance of the LILO and SILO transactions is a loan from
JH to the tax-indifferent entities. R argues in the alternative with
respect to the LILO and SILO transactions that at most P acquired a
future interest in the LILO and SILO assets.
The parties also dispute the location of JH's principal place of
business.
Held: JH's principal place of business is Boston,
Massachusetts.
Held, further, R failed to prove that the three LILO and four
SILO test transactions lack economic substance.
Held, further, the substance of the three LILO test transactions
is not consistent with their form. The LILO test transactions resemble
financial arrangements, and JH is therefore denied its claimed rental
expense, interest expense, and transaction cost deductions with
respect to them.
Held, further, the substance of three of the SILO test
transactions is consistent with their form; however, JH did not acquire
a present interest in the SILO test transaction properties and is
therefore denied its claimed depreciation and interest expense
deductions.
Held, further, the substance of the fourth SILO test transaction
is not consistent with its form. That SILO test transaction resembles
a financial arrangement, and JH is therefore denied its claimed
depreciation expense, interest expense, and transaction cost
deductions with respect to that transaction.
Held, further, JH had OID income with respect to the three
LILO test transactions and the fourth SILO test transaction but not
with respect to the first three SILO test transactions, in which it failed
to acquire a present interest.
-4Arthur L. Bailey, Jean A. Pawlow, James W. Johnson, Kevin J. Cloherty,
Alexis A. Maclvor, Thomas K. Spencer, and Nathaniel J. Dorfman, for
petitioners.
Daniel A. Rosen, Lyle B. Press, Steven N. Balahtsis, Allison Ickovic, and
Abigail F. Dunnigan, for respondent.
CONTENTS
FINDINGS OF FACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 12
Background ................................................. 12
I.
John Hancock'sHistory ............................. 12
II.
InvestmentProcess andReview ....................... 14
III.
Leasing .......................................... 16
IV.
LILOand SILOTransactions ......................... 16
A.
Basic Structure ............................... 16
B.
History ..................................... 24
C.
DueDiligence................................ 26
D.
The Hoosier Transaction ....................... 28
TheLILOTest Transactions .................................... 30
I.
OBBLILO ....................................... 31
-5-
A.
LeaseandSublease ........................... 31
1.
TheAsset .............................. 31
2.
Terms .................................33
3.
RentandFinancing ...................... 33
a.
b.
4.
5.
B.
Property Rights and Obligations . . . . . . . . . . . . 35
Default ................................36
EndofSubleaseTerm .........................37
1.
2.
II.
InitialLease ....................... 33
Sublease and Defeasance . . . . . . . . . . . . . 33
OBB'sPurchaseOption................... 37
JohnHancock'sOptions .................. 38
a.
RenewalOption .................... 38
b.
c.
ReplacementOption ................ 39
RetentionOption ................... 40
SNCB 2 and SNCB 5 Lot 1 LILO Transactions . . . . . . . . . . 40
A.
B.
Lease and Sublease . .. .... . . ............... ... 40
1.
The Assets ............................. 40
2.
3.
Terms .................................42
RentandFinancing ...................... 42
a.
InitialLease ....................... 42
b.
Sublease and Defeasance . . . . . . . . . . . . . 43
4.
Property and Default Rights and Obligations . . 44
End of Sublease Term . .. . . . . . . .. . . . . . ... .. . .. . 44
The SILOTestTransactions .................................... 45
I.
TIWAG .......................................... 46
A.
LeaseandSublease ........................... 46
1.
The Assets ............................. 46
2.
Terms ................................. 47
3.
RentandFinancing ...................... 47
a.
InitialLease ....................... 47
-6-
B.
II.
4.
b.
Sublease and Defeasance . . . . . . . . . . . . . 48
Property Rights and Obligations . . . . . . . . . . . . 51
5.
Default ................................52
EndofSubleaseTerm .........................53
1.
TIWAG'sPurchaseOption ................ 53
2.
John Hancock'sOptions .................. 53
TwoDortmundTransactions ......................... 56
A.
LeaseandSublease ........................... 56
1.
TheAsset .............................. 56
2.
Terms ................................. 58
3.
Rent and Financing ...................... 59
a.
InitialLease ....................... 59
b.
Sublease and Defeasance . . . . . . . . . . . . . 59
4.
B.
III.
Property and Default Rights and Obligations . . 61
EndofSubleaseTerm ......................... 61
SNCB SILO ...................................... 63
A.
GrantandSubgrant ........................... 63
1.
The Asset .............................. 63
2.
Terms ................................. 64
3.
Rent and Financing ..... ...... . ..... ..... 64
a.
Grant ..... .. .... .. .... . . ......... 64
4.
B.
b.
Subgrant and Defeasance . . . . . . . . . . . . 65
Property and Default Rights and Obligations . . 67
EndofSubgrantTerm ......................... 67
Tax Returns, Notices of Deficiency, and Trial . . . . . . . . . . . . . . . . . . . . . . 68
I.
Procedural History ................................. 68
A.
Notice of Deficiency (Docket No. 6404-09) . . . . . . . . 69
-7-
II.
B.
Notice of Deficiency (Docket No. 7084-10) . . . . . . . . 70
C.
Notice of Deficiency (Docket No. 7083-10) . . . . . . . . 72
D.
PretrialMotions .............................. 76
Trial............................................. 76
A.
B.
Petitioners' Expert Witnesses (Alphabetical Order) . . 77
1.
Mr.JohnDolan ......................... 77
2.
Dr. Paul Doralt . . .. .. .. . . . . . .. . . . . . . . .. . . 77
3.
Mr.Hans Haider......................... 78
4.
Dr.Friedrich Hey ........................ 78
5.
Dr.FriedrichPopp ....................... 79
6.
7.
8.
Dr. Thomas Schurrle . . . . . . . . . . . . . . . . . . . . . 79
Dr. Norbert Stoeck . . . . . . . . . . . . . . . . . . . . . . . 80
Dr. Frederik Vandendriessche . . . . . . . . . . . . . . 80
Respondent's Expert Witnesses (Alphabetical Order) 81
1.
Dr. IgnaasBehaeghe ..................... 81
2.
Dr. StefanDiemer ....................... 81
3.
Dr.MatthiasHeisse ...................... 81
4.
5.
6.
7.
8.
Dr. Thomas Lys ......................... 82
Dr.F.H. RolfSeringhaus .................. 83
Mag. Alexander Stolitzka . . . . . . . . . . . . . . . . . 83
Dr. Vukan Vuchic .................. ..... 84
Dr.PeterWundsam ......................84
OPINION ........................................................ 85
Burden ofProof..............................................85
PrincipalPlace ofBusiness ..................................... 86
LeveragedLease Transactions .................................. 87
I.
FrankLyon ....................................... 87
-8 -
II.
A.
Economic Substance .......................... 90
B.
SubstanceOverForm.......................... 92
LILOandSILOLitigation ........................... 93
A.
BB&T ..................................... 96
B.
AWG...................................... 100
C.
WellsFargo ................................ 106
D.
Altria...................................... 113
E.
Consolidated Edison ......................... 119
The Test Transactions ........................................ 125
I.
II.
Economic Substance ............................... 126
A.
ObjectiveInquiry ............................ 127
B.
SubjectiveInquiry ........................... 143
Substance OverForm ............................. 144
A.
OBB and SNCB LILO Transactions . . . . . . . . . . . . . 147
1.
B.
OBB Purchase Option Decision . . . . . . . . . . . 153
a.
Financial Considerations . . . . . . . . . . . . 159
b.
RetentionOption .................. 161
2.
c.
Renewal and Replacement Options . . . . 161
SNCB Purchase Option Decision . . . . . . . . . . 168
3.
Conclusion ............................ 176
SILOTest Transactions ....................... 177
1.
TIWAG and Dortmund Transactions . . . . . . . 179
a.
Sublease Term .................... 179
b.
PurchaseOptions .................. 183
-9I.
2.
TIWAG Transaction . . . . . . . . . . 184
c.
ii.
Dortmund Transactions . . . . . . . . 199
Service Contract Benefits and Burdens 213
d.
FutureInterest .................... 219
SNCB . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 222
a.
Purchase Option Decision . . . . . . . . . . . 223
b.
SubgrantTerm .................... 232
c.
Conclusion ....................... 235
InterestDeductions ..........................................236
Original Issue Discount . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 238
TransactionExpenses ........................................ 241
Conclusion................................................. 242
HAINES, Judge: These cases are consolidated for purposes of trial,
briefing, and opinion. Respondent determined the following deficiencies in
petitioners' Federal income tax for 19942 and 1997-2001 (years at issue):3
2Petitioners' 1994 deficiency arises from the denial of a claimed NOL
carryback.
3All section references are to the Internal Revenue Code (Code), as amended
and in effect for the years at issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure, unless otherwise indicated. Amounts are
rounded to the nearest dollar.
-10Year
Deficiency
1994
1997
1998
1999
2000
2001
$8,860,564
65,746,621
173,497,367
59,899,141
108,046,947
143,516,079
These deficiencies stem from 27 leveraged lease transactions (leveraged
leases) that petitioners participated in between 1997 and 2001. For purposes of
resolving this action expeditiously, the parties agreed to try seven of the leveraged
leases (test transactions) and apply a formula to determine the deficiency, if any,
with respect to the remaining leveraged leases. The test transactions comprise
three lease-in-lease-out (LILO) transactions and four sales-in-lease-out (SILO)
transactions.4
The test transactions were identified at trial and are referred to herein by the
lease counterparty to each transaction. The counterparties for the LILO test
transactions are: (1) Osterreichische Bundesbahnen (OBB), a Government-owned
Austrian corporation that operates the Austrian Federal railway system, and (2)
Societe Nationale des Chemins de Fer Belges (SNCB), a Belgian company that
4Petitioners have referred to the SILO transactions as "service contract"
transactions throughout the pleadings and at trial and have emphasized this
distinction from a LILO. For simplicity and without prejudice, we refer to these
transactions as SILO transactions.
- 11 owns and operates the national rail system of Belgium.5 The counterparties for the
SILO test transactions are: (1) Tiwag-Tiroler Wasserkraft AG (TIWAG), an
Austrian corporation that is owned by the Austrian Province of Tyrol and is in the
business of generating, transmitting, and distributing electrical power to
commercial and residential consumers in Tyrol; (2) the City of Dortmund,
Germany (Dortmund);6 and (3) SNCB.
The issues for decision are: (1) whether the principal place of business for
petitioner in docket No. 7083-10 was in Massachusetts or Michigan; (2) whether
the test transactions lacked economic substance resulting in disallowance of
petitioners' claimed deductions for rent, depreciation, interest, and transaction
expenses; (3) whether under the substance over form doctrine, the substance of the
5SNCB is the counterparty to two LILO test transactions. At trial and on
brief these LILO transactions were referred to as SNCB 2 and SNCB 5 lot 1. For
purposes of this Opinion, we refer to them individually in the same manner and
collectively as the SNCB LILO transactions.
6Dortmund is the counterparty to two SILO test transactions, referred to at
trial and on brief as the Dortmund 1 and Dortmund 2 transactions. The assets
subject to the Dortmund 1 transaction are Halls 1, 2, and 3A of the
Westfalenhallen Dortmund Trade Fair, Event, and Congress Center Complex and
the associated facility sites. The assets subject to the Dortmund 2 transaction are
Halls 4-8 of the Westfalenhallen Dortmund Trade Fair, Event, and Congress
Center Complex and the associated facility sites. In all other material respects,
Dortmund 1 and Dortmund 2 are identical. Therefore, for purposes of this
Opinion, we refer to them individually as Dortmund 1 and Dortmund 2, and
collectively as the Dortmund transactions.
- 12 test transactions was a purchase of a future interest, inconsistent with its form,
resulting in disallowance of petitioners' claimed deductions for rent, depreciation,
interest, and transaction expenses; or (4) alternatively, whether under the
substance over form doctrine, the substance of the test transactions was a
financing arrangement, inconsistent with its form, resulting in generation of
original issue discount (OID) income and the disallowance of petitioners' claimed
deductions for rent, depreciation, and interest expenses.
FlNDINGS OF FACT
Some of the facts have been stipulated and are so found. The stipulations of
fact, together with those attached exhibits which were found relevant and
admissible, are incorporated herein by this reference. At the time they filed their
petitions, the principal place of business of petitioners in docket Nos. 6404-09 and
7084-10 was in Massachusetts. There is a dispute among the parties as to whether
the principal place of business of petitioner in docket No. 7083-10 was in
Massachusetts or Michigan.
Background
I.
John Hancock's History
John Hancock Mutual Life Insurance Co. (JH Mutual) was incorporated in
Massachusetts in 1862. In February 2000 JH Mutual converted from a mutual life
- 13 insurance company to a publicly traded company. At that time it was renamed
John Hancock Life Insurance Co. (JHLIC) and became a wholly owned subsidiary
of John Hancock Financial Services, Inc. (JHFS). In April 2004 Manulife
Financial Corp., a Canadian company (Manulife), acquired JHFS and all of its
subsidiary corporations. Pursuant to a restructuring, on December 31, 2009, John
Hancock Life Insurance Co. (U.S.A.) (JHUSA) succeeded JHLIC. A subsidiary of
Manulife, the Manufacturer's Investment Co., a Michigan general business
corporation (MIC), succeeded JHFS. Unless otherwise indicated, for purposes of
this Opinion we refer to JH Mutual, JHLIC, JHFS, JHUSA, MIC, and their
subsidiaries collectively as John Hancock.
Throughout its history John Hancock's primary business has been the sale
of life insurance policies, annuities, long-term care insurance, and other retirement
services. To fulfill its contractual obligations under these services, John Hancock
invests the premiums it receives. Because of the varying lengths of John
Hancock's contractual obligations to its policyholders, it seeks to invest in
opportunities that match its long- and short-term cashflow needs and provide an
appropriate return or yield for its assessed risk levels.
John Hancock's financial needs require it to invest in a diversified set of
domestic and international assets. Between 1997 and 2001 John Hancock invested
- 14 between $6.8 and $10 billion annually and managed a portfolio of investments
valued between $38.9 and $46.6 billion.
II.
Investment Process and Review
Between 1997 and 2001 John Hancock's committee of finance oversaw its
investments. The committee of finance comprised members of John Hancock's
board of directors as well as its chairman, vice chairman, and president.
Committee of finance approval was required for all investments of a designated
s1Ze.
John Hancock's bond and corporate finance group managed the day-to-day
responsibilities with respect to a significant portion of the company's investments,
including bond portfolios, private equity, and alternative asset investments. The
bond and corporate finance group was divided into teams. For instance, the
"industrial" team was charged with managing investments in transportation,
timber, industrial equipment, mining, metal and communications assets. The
"energy" team managed investments in power plants, power companies, and other
energy assets. The "international" team managed cross-border investments. The
work of each team was connected to the "portfolio management" department,
which determined the types of investments and yields that John Hancock needed
to support its contractual obligations to its policyholders. The division of
- 15 responsibility within the bond and corporate finance group allowed each team to
specialize and develop an expertise in its designated industries.
Each of John Hancock's investments went through a thorough review
process. Typically, a bond and corporate finance group team was charged with
drafting an investment recommendation, known within John Hancock as a "yellow
report". A yellow report analyzes a proposed investment in numerous ways,
including an analysis of the expected return, risk profile, collateral support, credit
rating of the relevant parties to the transaction, term of the transaction, and any
special aspects of the investment. The yellow report was used as an approval
request for many of John Hancock's investments.
John Hancock's bond investment committee reviewed the yellow reports.
The bond investment committee held bimonthly meetings and comprised leaders
from each of the bond and corporate finance group's industry teams. At each bond
investment committee meeting, the credit analyst responsible for analyzing the
investment featured in the yellow report presented the opportunity, discussed the
risks and rewards of the investment, and fielded questions from the committee.
After review and consideration, the bond investment committee's members voted
to approve or deny an investment. If an investment was approved, it moved to the
committee of finance for further review and approval.
- 16 Generally, a committee of finance meeting was held once a month.
However, in certain circumstances the bond investment committee was granted
"between meeting authority" to enter into an investment normally requiring further
approval. "Between meeting authority" was necessary in cases where John
Hancock has to proceed with a time-sensitive investment.
III.
Leasing
In 1979 John Hancock formed a leasing company. Leasing transactions
were attractive to John Hancock because they offered a higher after-tax return than
traditional investments. A leveraged lease is a lease in which the equity investor
borrows money from a third-party lender to finance a portion of the purchase price
of the asset involved and leases the asset to its ultimate user. John Hancock
participated in leveraged leases as both equity investor and lender. A variety of
assets were involved, including aircraft, medical equipment, tractors, irrigation
systems, barges, trailers, grain silos, natural gas compressors, manufacturing
equipment, automobiles, and railcars.
IV.
LILO and SILO Transactions
A.
Basic Structure
John Hancock participated in 19 LILO transactions and 8 SILO transactions
between 1997 and 2001. LILO and SILO transactions are types of leveraged
- 17 leases. In a typical LILO transaction, a U.S. taxpayer, acting through a grantor
trust,7 leases assets from a foreign or domestic tax-exempt entity and
simultaneously leases that property back to the lessee 8 The U.S. taxpayer prepays
the initial lease's rent, which is funded through a nonrecourse loan from a thirdparty lender and an equity contribution from the U.S. taxpayer. The equity
ordinarily ranges from 10% to 20% of the value of the initial lease. Because the
loan funding the debt portion of the investment is nonrecourse, the U.S. taxpayer
is entitled to favorable accounting treatment on its financial statements pursuant to
Statement of Financial Accounting Standards No. 13 (FAS 13).9
The sublease has a shorter term than the initial lease. At the end of the
sublease term the tax-exempt entity has the option to purchase the remainder of the
U.S. taxpayer's leasehold interest in the initial lease. If the tax-exempt entity
7The grantor trust is generally disregarded for Federal income tax purposes.
8Each lessee counterparty to the test transactions is a foreign entity. These
foreign entities are so called tax-indifferent entities because they are not subject to
U.S. taxation. For convenience we shall refer to these entities as tax-exempt
entities.
9FAS 13 addresses lease accounting for lessors and lessees taking part in
leveraged leases. FAS 13 enables earlier recognition of income relative to other
transactions with similar cashflows. Additionally, FAS 13 allows nonrecourse
debt used in a leveraged lease to be excluded from the liabilities side of a balance
sheet.
- 18 -
chooses not to exercise this purchase option, the U.S. taxpayer may elect to: (1)
compel the tax-exempt entity to renew the sublease; (2) take possession of the
asset; or (3) enter into a replacement sublease with a third party. Most LILO and
SILO transactions impose requirements upon a tax-exempt entity that chooses not
to exercise its purchase option, such as refinancing the U.S. taxpayer's
nonrecourse loan. If the tax-exempt entity cannot meet these requirements, it must
ordinarily exercise the purchase option.
A typical SILO transaction is similar, except that the term of the initial lease
extends beyond the remaining useful life of the asset. Therefore, the U.S. taxpayer
takes the position that the initial lease is a sale for U.S. Federal tax purposes.
Also, if the tax-exempt entity chooses not to purchase the asset at the end of the
sublease term, the U.S. taxpayer's options differ slightly. The U.S. taxpayer may
(1) compel the lessee to arrange for a service contract for the asset for a
predetermined term or (2) take possession of the asset.
"Defeasance" is a common characteristic in most LILO and SILO
transactions. Defeasance is a way to minimize risk. The forin of the defeasance in
a particular LILO or SILO transaction will vary, but it is ordinarily accomplished
through one or more deposits with third-party financial institutions, known as
payment undertakers. In most LILO and SILO transactions the U.S. taxpayer will
- 19 require a debt payment undertaking agreement (DPUA) as part of the transaction,
and often will require an equity payment undertaking agreement (EPUA) as well.
In a DPUA, the tax-exempt entity deposits a portion of prepaid rent received from
the U.S. taxpayer funded by the nonrecourse loan with the debt payment
undertaker (DPU), sometimes related to the lender, and in return the DPU agrees
to make rent payments on behalf of the tax-exempt entity under the sublease. The
timing and amount of the tax-exempt entity's rent under the sublease usually
matches the U.S. taxpayer's debt service payments on the nonrecourse loan. As a
result, the DPU will often pay the lender directly and neither the U.S. taxpayer nor
the tax-exempt entity make any out-of-pocket payments during the initial lease
term.
In an EPUA, the tax-exempt entity deposits a portion of the U.S. taxpayer's
equity investment with an equity payment undertaker (EPU). This deposit is
designed to pay the tax-exempt entity's equity portion of rent payments, to grow to
cover the sublease termination value in case of a sublessee default, and to fund the
tax-exempt entity's purchase option at the end of the initial lease. As a result, the
tax-exempt entity is not forced to incur any additional out of pocket expenses if it
chooses to exercise its purchase option.
- 20 In addition to a DPUA and an EPUA, the U.S. taxpayer in a LILO or SILO
transaction may require additional protection, such as a pledge of the amounts
deposited pursuant to the DPUA or EPUA, or residual value insurance. If an
amount deposited with a payment undertaker is not pledged to the U.S. taxpayer,
the tax-exempt entity may have the right to withdraw the deposit for its own use if
it replaces the deposit with approved substitute collateral, such as a letter of credit.
The tax-exempt entity retains the portion of the equity contribution that is not
deposited pursuant to an EPUA. This amount is known as the tax-exempt entity's
"net present value benefit" from the transaction.
The following graphics display the closing day and sublease lease term
cashflowsl° and the operating structure of a basic single-lender LILO with debt
and equity defeasance during the sublease lease term. For purposes of this
graphic, the U.S. taxpayer's grantor trust is the lessor and the tax-exempt entity is
the lessee during the sublease lease term.
1°The graphic ignores transaction expenses that the U.S. taxpayer ordinarily
pays on the closing date.
- 21 -
Illustrative Hypothetical Closing Day Cashflows
US
Taxpayer
Equity
Contribution
($20)
Grantor
Trust
Nonrecourse
Loan
($80)
Lender
Equity Contribution+
Debt Contribution=
Prepaid Rent on Inital
Lease
($100)
Equity
Equity
Payment
Undertaker
Contribution -
Fee
Tax Exempt
Nonrecourse
Loan
Debt
($80)
Payment
Undertaker
Entity
($17)
Fee
($3)
The tax-exempt entity receives a fee for entering into the transaction with the
grantor trust. The equity contribution (minus the fee) will then be invested by the
equity payment undertaker and will be used to pay a portion of the sublease rent
payments and fund the purchase option at the end of the sublease term. The debt
contribution will be invested by the debt payment undertaker and will be used to
pay a portion of the sublease rent payments and eventually returned to the lender
as debt service payments on the nonrecourse loan. Typically the lender and the
debt payment undertaker are related parties, and often the equity payment
undertaker is also related to the lender.
- 22 -
Sublease Term Cashflows
Retum of
U.S.
Equity
Taxpayer 4 --- - - --
Grantor
Trust
Debt Service
Payment
- - -- -- ,
Return of Equity
Sublease Rent
Contribution
through Sublease
(Funded by Debt
Portion and Equity
Portion)
Lender
Sublease
Rent
Sublease
Equity
Tax Exempt
Rent
Debt
Payment - -- - -- V
Entity 4 - - - - Payment
Undertaker
(Fee)
Undertaker
The dashed lines represent the theoretical flow of cash from the payment
undertakers to the tax-exempt entity, the tax-exempt entity to the grantor trust, and
the grantor trust to the U.S. taxpayer and the lender. However, because the timing
and amount of the lessee's sublease rent payments and the lessor's debt service
payments match exactly, the debt payment undertaker often pays the lender
directly, satisfying both the sublease rent and the debt service payment. Similarly,
the equity payment undertaker's sublease rent ends up in the hands of the U.S.
taxpayer as a return of equity.
- 23 -
Closing Day Cashflows and Sublease Term Cashflows
Equity
Loop
US
Taxpayer
Equity
Contribution
Debt
Loop
.
. Grantor
Trust
Portion of equiíy
contribution
:
:
.
returned to U.S.
Taxpayer as
sublease rent
Equity
Payment
Undertaker
Equity
Contribution Fee
.
Lender
Equity Contribution+
Nonrecourse loan =
Prepaid Rent on Inital
: Lease
Tax Exempt.
Entit
.
Fee
.· Nonrecourse
Loan
Nonrecourse
Loan
Nonrecourse loan
returned to Lender
through sublease
rent payments
Debf
Payntent
Undertaker
-
Above is a combination of the closing day cashflows and the sublease term
cashflows. Together the two cashflows create what is known as loop debt.
-24B.
History
In 1975 the Internal Revenue Service (IRS) issued guidelines for advance
ruling purposes in determining whether leveraged lease transactions may be
treated as leases for Federal tax purposes. Rev. Proc. 75-21, 1975-1 C.B. 715. In
1981 Congress enacted safe harbor leasing rules for sale and leaseback
transactions that allowed taxpayers to lease property from tax-exempt entities.
Economic Recovery Tax Act of 1981, Pub. L. No. 97-34, 95 Stat. 172. These safe
harbor rules were repealed in 1982 because of adverse public reaction and reduced
tax revenues. Tax Equity and Fiscal Responsibility Act of 1982, Pub. L. No. 97248, 96 Stat. 324. In 1984 Congress enacted what has become known as the
"Pickle rule", which subjected property leased to a tax-exempt entity to
unfavorable depreciation rules. Deficit Reduction Act of 1984, Pub. L. No. 98-
369, 98 Stat. 494.
John Hancock began investing in LILO transactions in 1997. LILO
transactions were designed to work around the Pickle rule because the taxable
party leased the property involved, rather than purchasing it, and then immediately
subleased the property back to the tax-exempt entity. LILO transactions became
popular means of raising funds for tax-exempt entities. In fact, the Federal Transit
Administration (FTA) promoted and approved LILO and SILO transactions
- 25 between 1997 and 2001 as a means of providing cash infusions for financially
troubled public transit agencies.
In 1999 John Hancock and other similar investors ceased to invest in LILO
transactions because of a change to the regulations under section 467, requiring
that prepayment of the initial lease rent be treated as a loan for tax purposes. See
sec. 1.467-4, Income Tax Regs." In 2002 the IRS issued Rev. Rul. 2002-69,
2002-2 C.B. 760, which determined that a LILO transaction is more properly
characterized as a future interest in property and a taxpayer may not deduct rent or
interest paid or incurred in connection with such a transaction. The IRS further
stated that it would disallow tax benefits claimed in connection with LILO
transactions on other grounds, including the substance over form and economic
substance doctrines. Id.
Unable to continue investing in LILO transactions, John Hancock and other
similar investors began investing in SILO transactions. SILO transactions also
avoided the pitfalls of the Pickle rule because the service contract was arguably
not included in the lease term as long as it complied with section 7701(e). As a
"The IRS proposed regulations that largely eliminated the tax benefits
associated with LILO transactions in 1996; these regulations became effective in
1999.
- 26 result, SILO transactions were designed to allow the lessor to claim depreciation
deductions over a shorter term, increasing the transaction's tax value.
In 2004 Congress enacted the American Jobs Creation Act of 2004, Pub. L.
No. 108-357, 118 Stat. 1418, eliminating the benefits associated with LILO and
SILO transactions. This legislation was prospective in effect and was not
designed to alter the general principles of tax law that apply to determine the
legitimacy of transactions designed to generate tax deductions. See H.R. Conf.
Rept. No. 108-755, at 660 (2004), 2004 U.S.C.C.A.N. 1341, 1720-1721.
C.
Due Diligence
John Hancock learned of opportunities to invest in LILO or SILO
transactions from promoters such as D'Accord Financial Services and Citigroup.
A promoter acted as an adviser to the counterparties in these transactions, drafted
offering memoranda, and solicited offers or bids from potential investors. After
receiving an offering memorandum, John Hancock would prepare an offer that
was contingent on participation of the lenders at agreeable terms, completion of
internal and external due diligence, and the receipt of approved expert opinions
and reports. If John Hancock was chosen to participate in the transaction, it
engaged experts and attorneys to help negotiate a term sheet. John Hancock set
limitations for its total investments in LILO and SILO transactions between 1997
- 27 and 2001 that were based on its "tax capacity", which was determined on the basis
of its ability to offset its taxable income with losses.
As part of John Hancock's internal assessment of a LILO or SILO
transaction, the bond and corporate finance group drafted a yellow report. Each
transaction had to receive the approval of John Hancock's bond investment
committee and committee of finance. John Hancock generally chose to participate
in LILO and SILO transactions where its specialty groups had a familiarity with
the assets involved. Team members of the bond and corporate finance group
performed site visits and inspected many of the subject assets of the leveraged
leases.
John Hancock also engaged a team of independent specialists and
consultants as part of its due diligence process. These specialists and consultants
were relied upon to provide appraisals, accounting advice, insurance advice, legal
opinions, engineering opinions, and market analysis with respect to the relevant
industries. John Hancock also relied upon a financial modeling tool within the
leasing industry known as the ABC reports. Among other things, the ABC reports
projected John Hancock's pretax and after-tax financial consequences for each
transaction. The ABC reports provided alternative simulations based on the
assumption that the counterparty to each LILO or SILO transaction exercised its
- 28 purchase option and on the assumption that the counterparty did not exercise its
purchase option.
As part of John Hancock's internal risk assessment, John Hancock gave
each LILO and SILO transaction a credit rating based on the credit ratings of the
counterparties, the relevant defeasance, and the external specialty reports and
opinions. John Hancock's internal credit rating for each LILO transaction was
AA1, one grade below John Hancock's highest credit rating of AAA. John
Hancock's internal credit rating for each SILO transactions was AA3, a grade
slightly lower than AA1. John Hancock categorized its investments in LILO and
SILO transactions as bonds.
The securities valuation office of the National Association of Insurance
Commissioners (NAIC) evaluates and rates investments held by insurance
companies. Its highest rating is NAIC 1, which is given to transactions that
require the least amount of regulatory capital. Each of John Hancock's LILO and
SILO transactions was rated NAIC 1.
D.
The Hoosier Transaction
In 2008 the financial sector experienced a credit crisis. This crisis resulted
in widespread credit downgrades of financial institutions throughout the world,
including downgrades to the credit ratings of some of the payment undertakers and
- 29 insurance entities involved in John Hancock's LILO and SILO transactions. In
one such case, John Hancock was forced to litigate with an Indiana cooperative,
Hoosier Energy, over a SILO transaction involving a coal-fired power plant.
Hoosier Energy Rural Elec. Coop., Inc. v. John Hancock Life Ins. Co., 588 F.
Supp. 2d 919 (S.D. Ind. 2008), aff'd, 582 F.3d 721 (7th Cir. 2009).
In 2002 John Hancock entered into a SILO transaction with Hoosier in
which John Hancock leased a coal-fired power plant for 63 years and subleased it
back to Hoosier for 30 years. John Hancock's equity investment in the transaction
was $56,772,812. John Hancock also spent $12,830,640 in transaction expenses.
As part of John Hancock's security package, Hoosier obtained a credit default
swap from Ambac Assurance Corp. (Ambac). In 2008 Ambac's credit rating was
downgraded, and John Hancock exercised its right upon a credit downgrade under
the transaction documents to require Hoosier to replace Ambac. When Hoosier
was unable to replace Ambac within the specified period, John Hancock tried to
enforce its default rights.
Hoosier sought injunctive relief to prevent John Hancock from enforcing its
default rights while it continued to look for a replacement for Ambac. The District
Court for the Southern District of Indiana granted Hoosier's request for injunctive
relief, and the Court of Appeals for the Seventh Circuit affirmed, giving Hoosier
- 30 approximately 3½ months to find a replacement. During this period, John
Hancock and Hoosier settled their dispute. In this settlement, Hoosier agreed to
pay John Hancock $68 million.
The LILO Test Transactions
In connection with each of the test transactions John Hancock entered into
numerous agreements covering thousands of pages and conferring various rights
and obligations upon the parties involved." The general rights and obligations
created as part of each test transaction are similar. However, the details of those
rights and obligations vary from transaction to transaction. In each case, a
"participation agreement" governs the interaction of the agreements to the
transaction and provides, among other things, a general framework for the
transaction's structure. Each transaction includes numerous agreements, including
an initial lease and sublease, known as the "head lease" and the "lease" in some
cases. For simplicity and consistency, we refer to the head lease in each
John Hancock did not directly participate in any of the test transactions.
Rather, John Hancock established a grantor trust through which it participated.
These grantor trust are generally disregarded for Federal income tax purposes and
thus do not affect our analysis. Therefore, they are disregarded for purposes of
this Opinion.
- 31 transaction as the initial lease and the lease as the sublease." Our reference to the
transaction in this way is for convenience and is not dispositive of the status of a
transaction or the determination of the benefits and burdens of ownership. The
basic structures and relevant details of each of the LILO test transactions are
described below.
I.
OBB LILO
A.
Lease and Sublease
1.
The Asset
The OBB transaction closed on June 18, 1998. The asset subject to the
OBB transaction is the Vienna Kledering Marshalling Yard (VK marshalling
yard), which opened in 1996. Its primary function is "shunting", or the splitting
up of freight cars from incoming trains, sorting them, and attaching them to
outbound trains headed to their final destinations in Europe. The VK marshalling
yard has the capacity to process over 6,100 freight cars daily and is one of the
largest marshalling yards in eastern Europe.
"Each test transaction includes a tax indemnity agreement. The tax
indemnity agreements provide that the lessee counterparty will indemnify John
Hancock should John Hancock lose its rights to claim the expected tax benefits
from the test transactions because of certain enumerated reasons. Unlike the
taxpayer in Historic Boardwalk Hall, LLC v. Commissioner, 694 F.3d 425 (3d Cir.
2012), rev'g 136 T.C. 1 (2011), John Hancock is not protected if its tax benefits
are reduced as a result of an IRS challenge.
- 32 Deloitte & Touche (Deloitte) appraised the VK marshalling yard for the
OBB transaction at a fair market value, as of the closing date, of $352,711,000.
This value served as the basis for determining John Hancock's investment in the
initial lease. John Hancock and OBB did not further negotiate this investment
amount. The appraisal further determined that as of the closing date, the VK
marshalling yard had a remaining economic useful life of approximately 48 years.
The appraisal used both the cost method of valuation and the discounted cashflow
method in reaching its fair market value determination but based its conclusion on
the cost method because of a lack of reliable data with respect to expected
revenues and expenses from the VK marshalling yard. Deloitte also estimated the
residual value of John Hancock's remaining leasehold interest in the VK
marshalling yard at the end of the sublease term to be $105,107,878. The
appraisal relied upon the discounted cashflow method to reach this residual value
determination, stating that the cost approach was inapplicable and that the residual
value of John Hancock's remaining leasehold interest would depend upon the
cashflows the VK marshalling yard would generate during the remainder of the
initial lease term.
-332.
Terms
On the closing date, OBB leased the VK marshalling yard to John Hancock
for a term of approximately 38 years. Simultaneously, John Hancock subleased
the VK marshalling yard back to OBB for a term of approximately 18 years. At
the end of the sublease term OBB was given the option of purchasing John
Hancock's leasehold interest in the VK marshaling yard.
3.
Rent and Financing
a.
Initial Lease
The initial lease required John Hancock to make an up-front payment to
OBB of $309,375,024 and a deferred rent payment of $2,295,340,042 on
November 12, 2041, five years after the end of the initial lease term. To fund the
up-front payment, John Hancock contributed $65,980,517 and borrowed
$243,394,507 from Creditanstalt AG (Credit AG) on a nonrecourse basis. John
Hancock also paid $8,817,775 of transaction expenses.
b.
Sublease and Defeasance
Pursuant to the sublease, OBB agreed to pay rent to John Hancock. In order
to fund the sublease rent payments OBB entered into a number of defeasance
agreements. Pursuant to a DPUA, on the closing date OBB deposited the
$243,394,507 John Hancock borrowed from Credit AG and paid to OBB as an up-
- 34 front rent payment with CA-Leasing GmbH (CA Leasing), an affiliate of Credit
AG. In return, CA Leasing agreed to make a series of payments on behalf of OBB
which exactly match John Hancock's debt service payments to Credit AG in
amounts and timing. As a result, pursuant to the transaction documents, CA
Leasing pays Credit AG directly to satisfy John Hancock's debt service and
OBB's sublease rent.
Credit AG guaranteed CA Leasing's payments under the DPUA. The
DPUA and guaranty do not eliminate OBB's legal obligation to pay rent under the
sublease. In certain circumstances, OBB is entitled to replace the DPUA with
substitute collateral, including a qualified letter of credit.
On June 19, 1998, one day after the closing date, OBB entered into a swap
agreement with Merrill Lynch Capital Services, Inc. (Merrill Lynch). Pursuant to
this agreement, OBB paid Merrill Lynch $45,380,000 from John Hancock's
$65.,980,517 of equity contribution in exchange for Merrill Lynch's agreement to
make payments to OBB in accordance with a specified schedule, including
payments to fund OBB's purchase option if exercised. Further, an affiliate of
Merrill Lynch guaranteed Merrill Lynch's obligations pursuant to the swap
agreement. OBB pledged a first-priority security interest in the swap agreement to
John Hancock as collateral for its obligations under the sublease. OBB retained
- 35 the excess of the up-front rent payment from John Hancock to OBB pursuant to
the initial lease over the amounts OBB deposited with CA Leasing and Merrill
Lynch under the DPUA and swap agreement, respectively. This amount is OBB's
cash takeaway from the transaction, or what the parties refer to as OBB's "net
present value benefit".
On the closing date, OBB also provided John Hancock with a letter of credit
issued from Bank Austria Aktiengesellschaft (Bank Austria). Under the letter of
credit, Bank Austria is required to pay John Hancock a specified amount in the
event OBB defaults on its obligations pursuant to the sublease. This potential
payment eliminated any of John Hancock's risk of exposure that was not covered
under the DPUA and the swap agreement. The DPUA, swap agreement,
guaranties, pledge, and letter of credit were all required in the OBB transaction
under the participation agreement. As a result of the structure in place, the OBB
LILO transaction is fully defeased.
4.
Property Rights and Obligations
The initial lease grants John Hancock the right to "possession, use and quiet
enjoyment" of the VK marshalling yard. The initial lease is a net lease, meaning
that it requires John Hancock to insure, maintain, and repair the VK marshalling
yard. John Hancock may satisfy these requirements through its participation in the
- 36 sublease. John Hancock's participation in the sublease is required under the
participation agreement.
OBB's rights and obligations under the sublease with respect to possession
and use of the VK marshalling yard are nearly identical to John Hancock's rights
and obligations under the initial lease, including the right to "quiet enjoyment" of
the VK marshalling yard. The sublease grants OBB the right to modify the VK
marshalling yard, subject to certain restrictions. OBB is further restricted, with
certain exceptions, from subleasing the VK marshalling yard or creating or
permitting a lien on the VK marshalling yard. John Hancock has the right to visit
and inspect the VK marshalling yard.
5.
Default
If John Hancock defaults on its obligations under the initial lease, OBB may
require John Hancock to return the VK marshalling yard, terminate the lease, and
demand liquidated damages. In the "Event of Loss", the lease terminates and John
Hancock is required to pay a stipulated value to OBB. An "Event of Loss" is
defined to include, among other things, actual loss of the VK marshalling yard due
to damage or governmental seizure.
John Hancock's rights against OBB in the case of a lessee default under the
sublease are similar. John Hancock is entitled to collect on the "Termination
- 37 Value" of the sublease, take possession of the VK marshalling yard, sell the VK
marshalling yard, and terminate the sublease. The sublease termination value is
predetermined and is designed to provide John Hancock with a return on its equity
investment. In the case of an "Event of Loss" under the sublease, which is the
equivalent to the event of loss under the initial lease, the initial lease ends and
OBB must pay John Hancock the termination value. Additionally, all rents are
due from OBB to John Hancock, and OBB must pay John Hancock an additional
amount to offset the stipulated value John Hancock is required to pay OBB under
the initial lease.
B.
End of Sublease Term
1.
OBB's Purchase Option
At the end of the sublease term OBB has the option to purchase John
Hancock's leasehold interest in the VK marshalling yard for $153,817,825,
payable in predetermined installments. The payments due to OBB from CA
Leasing and Merrill Lynch match exactly the purchase option price and timing. If
OBB exercises its purchase option, all agreements executed pursuant to the OBB
LILO transaction will terminate and John Hancock will no longer be required to
pay OBB the deferred rent payment under the initial lease.
- 38 2.
John Hancock's Options
If OBB does not exercise its purchase option, John Hancock may choose
among three alternatives. John Hancock may elect to: (1) renew the sublease; (2)
replace OBB and lease the VK marshalling yard to another lessee; or (3) take
possession of the VK marshalling yard. In all three scenarios John Hancock must
provide OBB with acceptable collateral to secure John Hancock's obligations to
pay the deferred rent payment under the initial lease.
a.
Renewal Option
The renewal option extends John Hancock's sublease with OBB for
approximately 13 years and includes a set of prenegotiated rent payments during
the renewal term totaling $642,175,362. These rent payments have two
components. First, the current portion of renewal rent is equal to $213,241,461
and is payable throughout the renewal term. The remainder, or $428,933,901, is
deferred and payable at the end of the renewal term. Combined, these rent
payments ensure John Hancock's return on its equity investment. At the end of
the renewal term John Hancock would take possession of the VK marshalling yard
for the remainder of the initial lease term.
If John Hancock elects to renew the sublease, OBB must arrange for either
an extension of the nonrecourse loan from Credit AG to John Hancock or for
- 39 another lender to replace Credit AG as the lender under substantially the same
terms as the original loan. If OBB is unable to do so, it must purchase up to 49%
of the principal outstanding on the loan from Credit AG and attempt to again
extend the remaining loan or find a replacement lender. If OBB is still unable to
extend the loan or find a replacement lender, it again has the option of choosing to
exercise the purchase option.
If OBB elects the renewal option, it must also arrange for collateral
substantially identical to the swap agreement and letter of credit to secure the
equity portion of rent during the renewal term. OBB may also be required to
provide collateral to secure the debt portion of rent during the renewal term if the
replacement lender deems it necessary for the loan extension.
b.
Replacement Option
Under the replacement option, OBB must cooperate with John Hancock in
the negotiation, execution, and delivery of a replacement lease. However, John
Hancock bears the costs incurred in connection with the replacement lease. The
replacement lease does not have to mirror the renewal lease. John Hancock, and
not OBB, must arrange for a loan extension for its nonrecourse loan from Credit
AG or find a replacement lender. If John Hancock is unable to do so, it must
purchase the remaining principal of the loan from Credit AG. Further, if John
- 40 Hancock is unable to find a replacement lessee within 30 days of the end of the
sublease term, it will be deemed to have selected the renewal option.
c.
Retention Option
Under the retention option, John Hancock must arrange for payments in
satisfaction of the principal of its nonrecourse loan from Credit AG. If John
Hancock is unable to do so within 30 days of the end of the sublease term, it will
be deemed to have selected the renewal option.
II.
SNCB 2 and SNCB 5 Lot 1 LILO Transactions
A.
Lease and Sublease
1.
The Assets
The SNCB 2 and SNCB 5 lot 1 transactions closed on September 29 and
December 15, 1997, respectively. The Kingdom of Belgium owns 99.9% of
SNCB, which was reorganized as a limited liability company under Belgian public
law in 1991." SNCB operates and maintains domestic and international passenger
trains and freight rolling stock in Belgium. The asset subject to the SNCB 2
transaction is the Thalys highspeed trainset (Thalys trainset), which consists of
"In 2005 SNCB again reorganized with SNCB being renamed SNCB
Holding. Under the reorganization SNCB formed two subsidiaries, SNCB and
Infrabel, both public limited liability companies. For purposes of this analysis, we
refer to SNCB Holding and its subsidiaries as SNCB.
- 41 two power units and eight passenger cars, holds approximately 400 people, and is
used for highspeed international travel. The assets subject to the SNCB 5 lot 1
transaction are eight electric motive units (EMUs). The EMUs are three-car
trainsets consisting of a driving car and two trailer cars and are used
predominantly for intercity service.
Deloitte appraised the Thalys trainset at a fair market value of $34,267,200
on the closing date of the SNCB 2 transaction. Deloitte separately appraised the
EMUs at a fair market value of $61,371,200 on the closing date of the SNCB 5 lot
1 transaction. As in the OBB transaction, these values served as the basis for
determining John Hancock's investments in the transactions, and the parties did
not further negotiate the investment amounts. Deloitte concluded that as of the
closing dates of the SNCB 2 and SNCB 5 lot 1 transactions, the Thalys trainset
and the EMUs had remaining economic useful lives of 42 and 45 years,
respectively. The appraisals used both the cost method and the discounted
cashflow method in their fair market value determinations but chose to rely on the
cost method because of a lack of reliable data with respect to expected revenues
and expenses in connection with the assets. Deloitte also appraised John
Hancock's remaining leasehold interests in the Thalys trainset and EMUs at the
- 42 end of the subleases, estimating the residual values to be $7,774,387 and
$14,483,603,respectively.
2.
Terms
As part of the SNCB 2 transaction John Hancock leased the Thalys trainset
from SNCB for a term of approximately 34 years. Simultaneously, John Hancock
subleased the Thalys trainset back to SNCB for a term of approximately 15 years.
In the SNCB 5 lot 1 transaction John Hancock leased the EMUs from SNCB for a
term of approximately 34 years. Simultaneously, John Hancock subleased the
EMUs back to SNCB for a term of approximately 16 years. SNCB has the option
of purchasing John Hancock's leasehold interests in the Thalys trainset and EMUs
at the end of each transaction's sublease term.
3.
Rent and Financing
a.
Initial Lease
Similar to the OBB transaction, the initial lease in each of the SNCB LILO
transactions required John Hancock to make an up-front rent payment on the
closing date and a deferred rent payment five years after the end of each initial
lease term. John Hancock contributed $6,314,390 and $12,164,454 to the SNCB 2
and SNCB 5 lot 1 transactions, respectively, and borrowed $23,957,351 and
$42,725,648 to fund the remainder of the up-front payments on a nonrecourse
- 43 basis from Eurofima European Co. for the Financing of Railroad Rolling Stock
(Eurofima). John Hancock also paid transaction expenses of $733,318 and
$797,826 as part of the SNCB 2 and SNCB 5 lot 1 transactions, respectively.
b.
Sublease and Defeasance
Pursuant to the subleases, SNCB agreed to pay rent to John Hancock.
Similar to the OBB LILO, in order to fund its sublease rent payments SNCB
entered into a number of defeasance agreements. The debt defeasance in each
transaction is accomplished through a prepaid currency swap whereby SNCB and
Eurofima agreed to swap specified amounts of U.S. dollars for Belgian francs on
specified dates. Similar to the DPUA in the OBB transaction, the payments due
from Eurofima to SNCB exactly match John Hancock's debt service payments to
Eurofima in amount and timing.
The equity defeasance in each SNCB LILO transaction is governed by a
pledged collateral account agreement (PCAA) with Merrill Lynch. Pursuant to the
PCAAs, SNCB deposited a specified amount with Merrill Lynch to secure the
equity portion of sublease rent, sublease termination value, and the amount
required for SNCB's purchase options. John Hancock was granted a first-priority
security interest in each of the PCAAs. SNCB's net present value benefit in the
SNCB LILO transactions is the difference between John Hancock's up-front
- 44 payments under the initial leases and the respective amounts deposited and paid
pursuant to the currency swaps and PCAAs. As a result of the structure in place,
the SNCB LILO transactions are fully defeased.
4.
Property and Default Rights and Obligations
John Hancock's and SNCB's property and default rights and obligations
pursuant to the initial leases and subleases of the SNCB LILO transactions are
substantially similar to those conferred under the initial lease and sublease of the
OBB transaction. The most significant difference between the OBB transaction
and the SNCB LILO transactions is that in each of the SNCB LILO transactions
the counterparty, SNCB, has limited right under the subleases to replace the
subject assets.
B.
End of Sublease Term
According to the appraisals, the fixed purchase option price in each of the
SNCB LILO transactions is greater than the expected fair market values of the
respective assets on the purchase option dates. If SNCB exercises its purchase
options with respect to the SNCB LILO transactions, all agreements executed
pursuant to the transactions would terminate and John Hancock would no longer
be required to pay the deferred rent payments under the initial leases.
- 45 If SNCB does not exercise its purchase options, John Hancock may renew
the subleases, replace SNCB with a different lessee, or take possession of the
assets. The rights and obligations conferred upon John Hancock under each
option are substantially similar to those described with respect to the OBB
transaction.
The SILO Test Transactions
Several characteristics distinguish John Hancock's SILO transactions from
its LILO transactions. First, because the length of the initial lease exceeds the
estimated economic useful life of the asset, John Hancock treated each SILO
transaction as a sale for U.S. Federal tax purposes. Next, a service contract option
replaces the renewal and replacement leases if the lessee forgoes its purchase
option. And finally, pursuant to section 467 the sublease rent payments are treated
as a loan from the lessee counterparty to the U.S. taxpayer (section 467 loan).
Section 467 imputes a loan and adds an interest component to a lease in certain
cases where the allocation of rent payments does not match the dates when actual
payments are due. In the case of John Hancock's SILO transactions, the lessee
counterparties prepay their sublease rent payments, creating a section 467 loan
from the lessee counterparty to John Hancock.
-46-
I.
TIWAG
A.
Lease and Sublease
1.
The Assets
The TIWAG transaction closed on December 21, 2001. TIWAG is a
regional energy utility in the Province of Tyrol, Austria. The asset subject to the
TIWAG transaction is a 21.6% undivided interest in the Sellrain-Silz hydropower
facility (Sellrain-Silz). Sellrain-Silz is a pumped storage, hydroelectric generating
facility. The water powering the facility comes from an area covering 139 square
kilometers in the northern Stubai Alps. Sellrain-Silz is an important component in
TIWAG's power supply. According to the most recent public data, in 2008
Sellrain-Silz produced 21% of TIWAG's total power generation and 4% of
TIWAG's total power sold.
Deloitte appraised the 21.6% undivided interest in Sallrain-Silz as of the
closing date of the TIWAG transaction at a fair market value of $323,136,000,
with a remaining economic useful life of 75 years. This appraised fair market
value served as the basis for determining John Hancock's investment in the
transaction, and the parties did not further negotiate the investment amount.
Further, Deloitte estimated that as of the end of the sublease and service contract
terms the fair market value of the 21.6% undivided interest in Sellrain-Silz would
- 47 be $648,210,816 and $778,757,760, respectively. Deloitte used the discounted
cashflow method in its fair market value determinations.
2.
Terms
On the closing date John Hancock leased the 21.6% undivided interest in
Sellrain-Silz from TIWAG for a term of approximately 94 years. Simultaneously,
John Hancock subleased the 21.6% undivided interest in Sellrain-Silz to TIWAG
for a term of approximately 35 years. Because the term of the initial lease
exceeded its estimated remaining economic useful life, the parties treated it as a
sale for U.S. tax purposes. TIWAG has the option of purchasing John Hancock's
leasehold interest in Sellrain-Silz at the end of the sublease term.
3.
Rent and Financing
a.
Initial Lease
On the closing date John Hancock paid TIWAG $323 million pursuant to
the initial lease. To fund this payment, John Hancock contributed $49,427,050 in
equity and borrowed a total of $273,572,950 from two lenders on a nonrecourse
basis: $246,215,655 from Mercantile Leasing Co. (Mercantile) (series A loan) and
$27,357,295 from Bank Fur Tiroler Und Vorarlberg (BTV) (series B loan). John
Hancock paid $4,037,500 of transaction expenses.
- 48 b.
Sublease and Defeasance
Pursuant to the sublease, TIWAG agreed to pay rent to John Hancock. The
sublease required many of these payments to be made before the period to which
they were allocated. The prepayment of rent is treated as a loan from TIWAG to
John Hancock under section 467. At the end of the sublease term the section 467
loan balance is expected to be $636,037,102. In order to fund the sublease rent
payments, TIWAG entered into a number of defeasance agreements.
Unlike John Hancock's LILO transactions, the SILO transactions do not
require full defeasance. Rather, the transaction documents only require the
proceeds of the series A loan to be set aside pursuant to a DPUA. In the TIWAG
transaction, pursuant to the series A DPUA, TIWAG paid $246,215,655 to
Barclays Bank PLC (Barclays) on the closing date. In return, Barclays agreed to
make a series of payments on behalf of TIWAG which exactly match John
Hancock's debt service payments to Mercantile under the series A loan. As a
result, the transaction documents allow for payments directly from Barclays to the
series A lender, Mercantile, to satisfy John Hancock's series A debt service and a
portion of TIWAG's sublease rent. The series A DPUA is a three-party agreement
that includes John Hancock, providing John Hancock with a priority interest in the
deposit in the event TIWAG defaults on its sublease rent obligations.
- 49 Barclays is an affiliate of the series A lender, Mercantile. However,
Mercantile did not guarantee Barclay's payments under the series A DPUA.
TIWAG remains legally responsible for all rent and other obligations under the
sublease. In certain circumstances TIWAG may replace the series A DPUA with
substitute collateral, including a qualified letter of credit.
In addition to the series A DPUA, TIWAG entered into a series B DPUA
and an EPUA on the closing date. TIWAG's series B DPUA and EPUA were
arranged and agreed upon outside of the SILO transaction. The documents
governing the TIWAG transaction do not require these agreements. John Hancock
is not a party to either agreement, and neither is pledged to John Hancock.
Pursuant to the series B DPUA, TIWAG deposited $29,585,454 with Dexia
Credit Local (Dexia). In return Dexia agreed to make a series of payments on
behalf of TIWAG which exactly match John Hancock's debt service payments to
BTV under the series B loan. The payments from the series A DPUA and the
series B DPUA exactly satisfy TIWAG's debt portion of sublease rent." Dexia is
not an affiliate of BTV, the series B lender.
"Throughout the sublease term, TIWAG's sublease rent payments exceed
John Hancock's debt service payments by approximately $10 million. This $10
million is known as the "equity portion" of sublease rent.
- 50 Pursuant to the EPUA, TIWAG deposited $23.1 million with UBS AG
(UBS). In return UBS agreed to make a series of payments on behalf of TIWAG
pursuant to a specified schedule covering the equity portion of sublease rent and
funding a portion of TIWAG's purchase option if exercised. TIWAG's net present
value benefit in the transaction is approximately $24.1 million, equaling the
difference between John Hancock's investment in the initial leases, $323 million,
and the amounts paid to Barclays, Dexia, and UBS pursuant to the series A DPUA,
series B DPUA, and EPUA.
Although the series B DPUA and the EPUA were not required pursuant to
the TIWAG transaction documents, John Hancock knew of TIWAG's intention to
enter into such agreements because the defeasance agreements allowed TIWAG to
receive beneficial accounting treatment under European accounting principles
(European GAAP). Even if TIWAG decided not to enter into a series B DPUA
and EPUA on the closing date, the transaction documents required such
agreements or other similar qualifying collateral upon the occurrence of certain
trigger events such as a credit downgrade or majority ownership change in
TIWAG. As a precaution John Hancock preapproved a "form" of the series B
DPUA and the EPUA as well as Dexia and UBS as qualified payment undertakers.
- 51 The "form" series B DPUA and EPUA are identical to TIWAG's actual
agreements absent the information specific to the timing and participating parties.
4.
Property Rights and Obligations
The initial lease grants John Hancock the right to use, operate, maintain or
possess the 21.6% undivided interest in Sellrain-Silz. During the initial lease term
TIWAG cannot sell, dispose of, or create a security interest in the property without
John Hancock's consent. The initial lease also restricts TIWAG's rights to
consolidate or merge with another company or spin off, convey, transfer, or lease
substantially all of its assets to another party.
TIWAG's rights and obligations under the sublease with respect to
possession and use of the 21.6% undivided interest in Sellrain-Silz are nearly
identical to John Hancock's rights and obligations under the initial lease. The
sublease is a net lease, meaning that TIWAG is responsible for maintenance,
insurance, and operational costs. During the sublease term TIWAG generally
cannot create or permit any lien on the 21.6% undivided interest in Sellrain-Silz.
John Hancock has the right to visit and inspect Sellrain-Silz twice a year.
On the closing date John Hancock and TIWAG also entered into an
"Agreement of Servitude" pursuant to which TIWAG granted John Hancock a
right-of-way to specified land parcels at Sellrain-Silz (ROW agreement). The
- 52 ROW agreement provides John Hancock access to the road that leads from the
public.road to the upper dam of Sellrain-Silz. This right-of-way was registered
with the land registry at the district court in Silz, Austria. Upon the occurrence of
a "Trigger Event", John Hancock has the right to purchase certain parcels of land
related to Sellrain-Silz. A trigger event includes, among other things, TIWAG's
selling or imposing a mortgage or pledge on specified land connected with
Sellrain-Silz.
5.
Default
Neither John Hancock nor TIWAG has the right to declare the initial lease
in default and pursue remedies. However, under the sublease, John Hancock has
certain remedies against TIWAG in the case of a "Lessee Event of Default". In
such a case, John Hancock is entitled to collect on the "Termination Value" of the
sublease. John Hancock may also take possession of, sell, or sublease the 21.6%
undivided interest in Sellrain-Silz. . Just as in John Hancock's LILO transactions,
termination value is predetermined on the closing date and ensures John
Hancock's return on its equity investment. TIWAG must also pay John Hancock
the termination value in the case of a "Lease Event of Loss", which includes actual
loss or seizure of Sellrain-Silz.
- 53 B.
End of Sublease Term
1.
TIWAG's Purchase Option
At the end of the sublease term TIWAG has the option of purchasing John
Hancock's leasehold interest in Sellrain-Silz for $795,135,940. If TIWAG
exercises the purchase option, John Hancock must pay TIWAG the amount due
under the section 467 loan, and all agreements executed pursuant to the TIWAG
transaction would terminate. The section 467 loan balance exactly matches the
first installment of the purchase option. Therefore, if TIWAG exercises its
purchase option, these amounts offset each other. The remaining installments of
the purchase option price are f'manced through TIWAG's EPUA, meaning that if
TIWAG exercises the purchase option, it does not have to contribute or borrow
any additional cash.
2.
John Hancock's Options
If TIWAG does not exercise its purchase option, John Hancock has two
choices. First, it may elect to require TIWAG to arrange for a service contract
between John Hancock and one or more power purchasers. Second, it may elect to
take possession of the 21.6% undivided interest in Sellrain-Silz. In either case,
TIWAG must ensure at its own expense that Sellrain-Silz is in satisfactory
condition in accordance with all regulatory and other requirements.
- 54 Similar to the LILO test transactions, neither party has advanced a
compelling reason John Hancock would select the retention option in any of the
SILO test transactions. Therefore, as the parties have, we focus our discussion for
each SILO test transaction on the service contract option.
Under the service contract option, TIWAG must procure one or more
"Qualified Bidders" to enter into one or more power purchase agreements with
John Hancock and arrange for an operator of the 21.6% undivided interest in
Sellrain-Silz during the service contract term. TIWAG must also find a bank to
refinance the section 467 loan. A qualified bidder cannot be the operator or be
related to the operator of Sellrain-Silz. TIWAG may be the power purchaser or
the operator but not both. The power purchase agreements must match the service
contract term which is prearranged on the closing date to be approximately 25
years.
Any power purchaser must agree to make a series of predetennined
payments throughout this term, known as the "Capacity Charges". These
payments total $1,316,013,696. A power purchaser is also required to pay for
John Hancock's fixed and variable cost of operating the 21.6% undivided interest
in Sellrain-Silz. The capacity charges are set at amounts that reflect the future fair
market value of the asset and cover John Hancock's cost of servicing the
- 55 refinanced section 467 loan while paying John Hancock a specified return. If John
Hancock fails to make the required capacity available to the service purchaser for
any reason, including force majeure, the capacity charges will be reduced in a
manner consistent with the service contract. The power purchase agreements do
not require credit support to secure the power purchaser's payments during the
service contract term. However, if at any point during the service contract term a
power purchaser's credit rating were to fall below A or A2 under S&P's and
Moody's credit rating systems, respectively, that power purchaser would be
required to procure credit support in the form of a letter of credit or guaranty from
a bank or guarantor with the requisite credit rating.
John Hancock may also request that TIWAG acquire residual value
insurance to protect a portion of the value of the 21.6% undivided interest in
Sellrain-Silz at the end of the service contract term. The amount of the residual
value insurance is the lesser of: (1) $205,422,256 or (2) 35% of the appraised fair
market value of the 21.6% undivided interest in Sellrain-Silz at the end of the
service contract term as determined at or near the purchase option date. From the
end of the service contract term to the end of the initial lease John Hancock would
take possession of the 21.6% undivided interest in Sellrain-Silz to use as it
pleases.
- 56 If TIWAG fails to find qualified bidders to enter into the power purchase
agreements or fails to procure a bank to refinance the section 467 loan, it may cure
this failure through the exercise of its purchase option. If TIWAG is able to
satisfy all the required conditions and a power purchase agreement is in place, it
will receive the proceeds of the section 467 loan from John Hancock as well as the
balance of the EPUA.
II.
Two Dortmund Transactions
A.
Lease and Sublease
1.
The Asset
The Dortmund transactions closed on December 20, 2001. The assets
subject to the Dortmund transactions are halls 1, 2, 3A, and 4-8 of the
Westfalenhallen Dortmund Trade Fair, Event, and Congress Center Complex
(trade fair facility). Dortmund is in the State of North Rhine-Westphalia,
Germany. Westfalenhallen Dortmund GmbH (Westfalenhallen), a German limited
liability company, operates the trade fair facility through its subsidiaries, and
Dortmund is the sole owner of Westfalenhallen. The trade fair facility presents
more than 30 national and international trade fairs each year. In 2000, the year
before John Hancock entered into the Dortmund transactions, more than 7,000
exhibitors and more than 1 million visitors came to Dortmund for events hosted in
- 57 the trade fair facility. In 2004 Dortmund constructed hall 3B as an addition to the
trade fair facility, which is not and was never made part of the Dortmund
transactions. John Hancock and Dortmund executed servitude consent agreements
so that the new hall would not adversely affect John Hancock's interest in the
trade fair facility.
Deloitte appraised the trade fair facility. As of the closing date of the
Dortmund transactions, the appraisalsl6 concluded that the halls subject to the
transactions had the following fair market values and remaining economic useful
lives:
Hall
Fair market value
Remaining useful
life in years
1
2
3A
4
5
6
7
8
$31,661,000
10,295,000
4,588,000
23,249,000
13,910,000
22,330,000
17,835,000
15,160,000
60
55
55
60
55
62
62
68
The appraisals were used to determine John Hancock's investment in the
transactions, and the parties did not further negotiate the investment amounts.
16Deloitte issued one appraisal for halls 1, 2, and 3A of the trade fair facility
and a second appraisal for halls 4-8.
- 58 According to the appraisals, as of the purchase option date the expected fair
market value of the trade fair facility was determined to be $242,882,556. The
methodology used in the appraisals attributed 80% of the fair market value
determinations to the discounted cashflow method and 20% to the cost method.
2.
Terms
On the closing date John Hancock leased the trade fair facility from
Dortmund for a term of 99 years. Simultaneously, John Hancock subleased the
trade fair facility to Dortmund for a term of approximately 30 years. This
arrangement required multiple agreements to incorporate the entire trade fair
facility. In each transaction, an initial lease and sublease govern the parties' rights
and obligations with respect to the halls. With respect to the facility sites
associated with each hall, the parties entered into a "Facility Site Lease
Agreement" for each transaction. Unless otherwise stated, there are no material
rights and obligations conferred, pursuant to each facility site lease, that
distinguish the Dortmund transactions from John Hancock's other SILO test
transactions for purposes of this Opinion. Dortmund has the option of purchasing
John Hancock's leasehold interests in the trade fair facility at the end of the
sublease term.
- 59 3.
Rent and Financing
a.
Initial Lease
On the closing date of the Dortmund transactions John Hancock made
payments to Dortmund of $46,544,000 and $92,484,000 pursuant to the initial
lease agreements and facility lease agreements of the Dortmund 1 and Dortmund 2
transactions, respectively. To fund these payments, John Hancock contributed
$7,379,928 for the Dortmund 1 transaction and $14,652,452 for the Dortmund 2
transaction. John Hancock also borrowed approximately 90% of the debt from
Mercantile, equal to $35,247,665 and $70,048,393 for the respective transactions
(series A loans). The remaining 10% was borrowed from Westdeutsche
Landesbank Girozentrale (series B loans). John Hancock also paid transaction
expenses of $1,373,048 and $2,728,730 as part of the Dortmund 1 and Dortmund
2 transactions, respectively.
b.
Sublease and Defeasance
Pursuant to the sublease agreements, Dortmund agreed to pay rent to John
Hancock. As in the TIWAG transaction, the sublease agreements require that
many of these payments be made before the period to which they are allocated,
resulting in section 467 loans to John Hancock in each transaction. On the
purchase option date, the total balance of the section 467 loans is expected to be
- 60 approximately $221,835,000. In order to fund the sublease rent payments
Dortmund entered into a number of defeasance agreements.
On the closing date Dortmund entered into a series A DPUA with Barclays
for each of the Dortmund transactions. The series A DPUAs are substantialvly
similar to the series A DPUA in the TIWAG transaction. With respect to the
series B loan and equity, just as in the TIWAG transaction, the Dortmund
transactions do not require Dortmund to enter into a series B DPUA or an EPUA.
John Hancock is not a party to a series B DPUA or EPUA, and John Hancock is
not the beneficiary of a pledge of a series B DPUA or EPUA. Nonetheless,
Dortmund defeased the series B loans and equity in agreements executed outside
of the Dortmund transactions. Dortmund's net present value benefit in each
transaction is equal to its up-front payments under the initial leases less the
amount that was deposited pursuant to the series A DPUAs, series B DPUAs, and
EPUAs.
Dortmund entered into a series B DPUA with Hypo-und Vereinsbank AG
for each of the Dortmund transactions. Dortmund also entered into numerous
EPUAs with Bank Austria. As in the TIWAG transaction, the series B DPUAs
and EPUAs entitle Dortmund to beneficial accounting treatment under European
GAAP. John Hancock knew that Dortmund intended on entering into such
- 61 agreements because John Hancock preapproved a "form" of the EPUAs as well as
Bank Austria as the EPUA undertaker. The EPUAs were required under the
participation agreement upon the occurrence of certain trigger events. There are
no trigger events that would require Dortmund to enter into the series B DPUAs.
Nonetheless, John Hancock approved a "form" for the series B DPUAs.
4.
Property and Default Rights and Obligations
John Hancock and Dortmund's property and default rights and obligations,
pursuant to the Dortmund transactions' initial leases, facility site leases, and
sublease agreements, are substantially similar to those conferred under the initial
lease and sublease in the TIWAG transaction.
B.
End of Sublease Term
Dortmund has a purchase option at the end of each transaction's sublease
term which is designed in a manner consistent with the TIWAG transaction. If
Dortmund does not exercise its purchase options, John Hancock must choose
between requiring Dortmund to arrange for a service contract or take possession of
the trade fair facility itself.
Under the service contract option Dortmund must procure one or more
service purchasers for the trade fair facility. The service purchasers must agree to
pay service fees that consist of: (1) the annual capacity availability charges that
- 62 -
are designed to cover John Hancock's debt service on the refinanced section 467
loan and ensure a predetermined economic return on its investment and (2) the
trade fair facility operating and maintenance expenses. Dortmund may remain the
operator of the trade fair facility or must find a qualified replacement operator.
Unlike the TIWAG transaction, Dortmund may be both the service purchaser and
the operator.
If John Hancock fails to make the trade fair capacity and management
services available to the service purchasers for any reason, including force
majeure, the capacity availability charges will be reduced in a manner consistent
with the service contract. The service contract does not require credit support to
secure a service purchaser's payments during the service contract term. However, .
if at any point during the service contract term a service purchaser's credit rating
were to fall below BBB+ or Baal under S&P's and Moody's credit rating systems,
respectively, the service purchaser is required to procure acceptable credit support.
In all other ways, the design, structure, and economics of John Hancock's service
contract options and retention options in the Dortmund transactions are
substantially similar to those of the TIWAG transaction.
- 63 III.
SNCB SILO
A.
Grant and Subgrant
1.
The Asset
The SNCB SILO closed on November 14, 2001. The asset subject to the
SNCB SILO is a 50% undivided interest in the high-speed rail line that runs from
the Belgian-French border to Lembeek, Belgium, and the railway station known as
"Brussels South" that is dedicated to that high-speed line (together the HSL). The
HSL is integrated with the main east-west rail line in Belgium. SNCB considers
the HSL to be its "crown jewel" as it enables high-speed rail services between the
United Kingdom, France, the Netherlands, and Germany.
Deloitte appraised the HSL and concluded that as of the closing date, a 50%
undivided interest in the HSL had a fair market value of $426,900,500 and a
remaining economic useful life of 78 years. This value served as the basis for
determining John Hancock's investment in the SNCB SILO, and the parties did
not further negotiate the investment amount. Deloitte further appraised the 50%
undivided interest in HSL as of the purchase option date at $890,941,344. The
appraisal used the discounted cashflow method in its fair market value
determinations.
-642.
Terms
On the closing date John Hancock entered into a grant of rights agreement
with SNCB with respect to the 50% undivided interest in HSL for a term of
approximately 99 years (grant). Simultaneously, John Hancock and SNCB entered
into a subgrant of rights agreement for a term of approximately 29 years (subgrant)
whereby John Hancock granted a set of nearly identical rights in the 50%
undivided interest in HSL back to SNCB.4 SNCB has the option of purchasing
John Hancock's interest in the HSL at the end of the subgrant term.
3.
Rent and Financing
a.
Grant
On the closing date John Hancock paid $426,900,500 to SNCB pursuant to
the grant. To fund this payment John Hancock contributed $61,177,535 in equity
and borrowed a total of $365,722,965 from two lenders on a nonrecourse basis,
$329,150,668 from Mercantile (series A loan) and $36,572,297 from Barclays
(series B loan). John Hancock also paid $3,799,414 of transaction expenses.
"For purposes of this analysis, there are no material differences between the
function of the grant of rights and the subgrant used in the SNCB SILO and the
leases and subleases used in John Hancock's other SILO test transactions.
- 65 b.
Subgrant and Defeasance
Pursuant to the subgrant SNCB agreed to make subgrant rent payments to
John Hancock in the amounts and on the dates specified in the sublease agreement.
The sublease requires that many of these payments be made before the period to
which they are allocated. As in John Hancock's other SILO test transactions, this
prepayment creates a section 467 loan. At the end of the sublease term the section
467 loan balance is expected to be $780,056,766. In order to fund the subgrant
rent payments SNCB entered into a number of defeasance agreements.
On the closing date, SNCB entered into a series A DPUA with Barclays.
The series A DPUA is substantially similar to those in John Hancock's other SILO
test transactions. Also as in John Hancock's other SILO test transactions, the
SNCB SILO transaction does not require SNCB to enter into a series B DPUA or
an EPUA. John Hancock is not a party to a series B DPUA or an EPUA, and John
Hancock is not the beneficiary of a pledge of a series B DPUA or EPUA.
On November 19, 2001, SNCB entered into a currency swap transaction
(CST) with Bank of America, NA (BofA). Pursuant to the currency swap
transaction, SNCB agreed to pay BofA U.S.-dollar-denominated payments on
certain specified dates in exchange for euro-denominated payments. The
payments made to SNCB under the currency swap transaction match the debt
- 66 service payments on the series B loan. Unlike the currency swap transactions in
the SNCB LILO transactions, SNCB did not prepay this currency swap.
Also on November 19, 2001, SNCB entered into a USD Credit Linked
Deposit Agreement with UBS (CLDA). Similar to the EPUAs in John Hancock's
other SILO test transactions, SNCB placed a deposit with UBS in exchange for a
series of payments exactly matching the timing and amount of the equity subgrant
payments and the purchase option price. SNCB may not freely terminate the
CLDA.18 However, the CLDA permits SNCB to direct the payments due from
UBS to the recipient of its choosing. As in John Hancock's other SILO test
transactions, the CLDA entitled SNCB to beneficial accounting treatment under
European GAAP, and John Hancock knew that SNCB intended on executing such
an agreement. SNCB calculated its net present value benefit from the transaction
as the difference between the $426,900,500 received from John Hancock pursuant
to the grant and the amounts paid upon the execution of the series A DPUA, the
CLDA, and the CST.
'8Petitioners argue that SNCB may terminate the CLDA at any time to free
up cash for its general business purposes. To support this argument, petitioners
rely solely on the testimony of an SNCB executive. This testimony is not
consistent with the terms of the CLDA.
- 67 4.
Property and Default Rights and Obligations
For purposes of this analysis the property and default rights and obligations
of John Hancock and SNCB, with respect to the grant and subgrant, are
substantially similar to those conferred under the initial leases and subleases in
John Hancock's other SILO test transactions. The primary difference in the SNCB
. SILO transaction is that HSL is part of the Belgian public domain. Consequently,
the parties included provisions in the transaction documents providing that if HSL
ceases to be an asset in the public domain, the parties intend for all of the
transaction documents to survive and the rights and obligations of the parties to
constitute an independent contractual relationship.
B.
End of Subgrant Term
SNCB has a purchase option at the end of the subgrant term under
substantially the same terms and conditions as in John Hancock's other SILO test
transactions. Further, as in those transactions, if SNCB does not exercise its
purchase option, John Hancock must choose between requiring SNCB to arrange
for a service contract or taking possession of the 50% undivided interest in HSL.
Under the service contract option SNCB must procure a "Service
Purchaser" under the service contract, which cannot be SNCB, and arrange for the
section 467 loan to be refinanced. John Hancock must find an operator for the
- 68 50% undivided interest in HSL; but if it cannot find a suitable operator, SNCB is
required to assume the position. Under the service contract the service purchaser
must agree to pay John Hancock: (1) the base service fees, which are designed to
cover John Hancock's debt service on the refinanced section 467 loan and ensure a
predetermined economic return on its investment and (2) the monthly additional
fees that cover the fixed and variable costs of operating the 50% undivided interest
in HSL.
The service purchaser has the right to terminate the service contract if John
Hancock fails to make the asset available for the negotiated services for any
reason, except for force majeure, and fails to cure within 60 days of notification.
In the case of force majeure, the service purchaser may terminate the service
contract if John Hancock fails to cure within 180 days. In all other ways, the
design, structure, and economics of John Hancock's service contract option and
retention option are substantially similar to those of John Hancock's other SILO
test transactions.
Tax Returns, Notices of Deficiency, and Trial
I.
Procedural History
John Hancock filed a consolidated Federal income tax return for each of the
years at issue.
- 69 A.
Notice of Deficiency (Docket No. 6404-09)
On December 17, 2008, respondent issued a notice of deficiency to John
Hancock which determined Federal income tax deficiencies for 1994, 1997, and
1998 of $8,860,564, $65,746,621, and $173,497,367, respectively, based upon the
disallowance of various deductions and adjustments to gross income from John
Hancock's LILO transactions and the denial of a capital loss carry back to 1994.
On March 16, 2009, John Hancock filed the petition with this Court at docket No.
6404-09, disputing the 1994, 1997, and 1998 determined deficiencies.
The notice of deficiency for docket No. 6404-09 included three of the test
transactions litigated in these cases, the OBB LILO and the two SNCB LILOs.1°
With respect to the OBB LILO, respondent determined that the LILO transaction
was in substance the purchase of a future interest by John Hancock and therefore
denied John Hancock's deductions of $66,899,067 for a rental expense,
$15,946,722 for an interest expense, and $298,054 for amortized transaction costs
for 1998. Additionally, respondent reduced John Hancock's taxable rental income
by $19,169,206 for 1998. Alternatively, respondent determined that in substance
the OBB LILO transaction was a financing arrangement and therefore increased
John Hancock's taxable income by $1,040,159 for OID income for 1998. Under
19The nOtiCe Of defiCiency Combined the two SNCB LILO transactions.
- 70 this alternative argument, respondent concedes John Hancock's deduction for
amortized transaction costs.
With respect to the two SNCB LILOs, respondent determined that the LILO
transactions were in substance purchases of future interests by John Hancock and
therefore denied John Hancock's deductions of $6,849,494 and $39,408,434 for
rental expenses, $1,737,691 and $10,030,464 for interest expenses, and $23,787
and $127,220 for amortized transaction costs for 1997 and 1998, respectively.
Additionally, respondent reduced John Hancock's taxable rental income by
$2,265,498 and $13,298,535 for 1997 and 1998, respectively. Alternatively,
respondent determined that in substance the two SNCB LILO transactions were a
financing arrangement and therefore increased John Hancock's taxable income by
$229,736 and $1,929,488 for OID income for 1997 and 1998, respectively. Under
this alternative argument, respondent concedes John Hancock's deduction for
amortized transaction costs.20
B.
Notice of Deficiency (Docket No. 7084-10)
On December 24, 2009, respondent issued a notice of deficiency to John
Hancock which determined a Federal income tax deficiency for 1999 of
20Respondent made similar determinations and denied similar deductions for
the six other LILO transactions listed in the notice of deficiency.
- 71 $59,899,141 based upon the disallowance of various deductions and adjustments
to gross income from John Hancock's LILO transactions. On March 23, 2010,
John Hancock filed the petition with this Court at docket No. 7084-10, disputing
the 1999 determined deficiency.
The notice of deficiency for docket No. 7084-10 included three of the test
transactions litigated in these cases, the OBB LILO and the two SNCB LILOs."
With respect to the OBB LILO, respondent determined that the LILO transaction
was in substance the purchase of a future interest by John Hancock and therefore
denied John Hancock's deductions of $124,785,824 for a rental expense,
$29,516,300 for an interest expense, and $555,956 for amortized transaction costs
for 1999. Additionally, respondent reduced John Hancock's taxable rental income
by $35,739,244 for 1999. Alternatively, respondent determined that in substance
the OBB LILO transaction was a financing arrangement and therefore increased
John Hancock's taxable income by $4,746,135 for OID for 1999. Under this
alternative argument, respondent concedes John Hancock's deduction for
amortized transaction costs.
With respect to the two SNCB LILO transactions, respondent determined
that the LILO transactions were in substance the purchase of a future interest by
The notice of deficiency combined the two SNCB LILO transactions.
- 72 John Hancock and therefore denied John Hancock's deductions of $39,408,436 for
a rental expense, $9,787,937 for an interest expense, and $127,220 for amortized
transaction costs for 1999. Additionally, respondent reduced John Hancock's
taxable rental income by $13,298,535 for 1999. Alternatively, respondent
determined that in substance the two SNCB LILO transactions were financing
arrangements and therefore increased John Hancock's taxable income by
$2,055,293 for OID income for 1999. Under this alternative argument, respondent
concedes John Hancock's deductions for amortized transaction costs.22
C.
Notice of Deficiency (Docket No. 7083-10)
On December 24, 2009, respondent issued a notice of deficiency to John
Hancock which determined Federal income tax deficiencies for 2000 and 2001 of
$108,046,947 and $143,516,079, respectively, based upon the disallowance of
various deductions and adjustments to gross income from John Hancock's LILO
and SILO transactions and the denial of worthless stock losses for 2000.23 On
March 23, 2010, John Hancock filed the petition with this Court at docket No.
7083-10, disputing the 2000 and 2001 determined deficiencies.
22Respondent made similar determinations and denied similar deductions for
the six other LILO transactions listed in the notice of deficiency.
23The parties filed a stipulation of settled issues with the Court on June 7,
2011, resolving the worthless stock loss issue for 2000.
- 73 The notice of deficiency for the case at docket No. 7083-10 included all
seven of the test transactions litigated in these cases, the OBB LILO, the two
SNCB LILOs," the TIWAG SILO, the two Dortmund SILOs," and the SNCB
SILO. With respect to the OBB LILO, respondent determined that the LILO
transaction was in substance the purchase of a future interest by John Hancock and
therefore denied John Hancock's deductions of $124,785,824 and $124,785,724
for rental expenses, $29,073,071 and $28,598,273 for interest expenses, and
$555,956 and $555,956 for amortized transaction costs for 2000 and 2001,
respectively. Additionally, respondent reduced John Hancock's taxable rental
income by $35,739,244 and $35,739,244 for 2000 and 2001, respectively.
Alternatively, respondent determined that in substance the OBB LILO transaction
was a financing arrangement and therefore increased John Hancock's taxable
income by $4,044,640 and $5,361,948 for OID income for 2000 and 2001,
respectively. Under this alternative argument, respondent concedes John
Hancock's deduction for amortized transaction costs.
With respect to the two SNCB LILO transactions, respondent determined
that the LILO transactions were in substance purchases of future interests by John
"The notice of deficiency combined the two SNCB LILO transactions.
"The notice of deficiency combined the two Dortmund SILO transactions.
- 74 Hancock and therefore denied John Hancock's deductions of $39,408,436 and
$38,940,891 for rental expenses, $9,527,327 and $9,068,703 for interest
expenses, and $127,220 and $127,220 for amortized transaction costs for 2000 and
2001, respectively. Additionally, respondent reduced John Hancock's taxable
rental income by $13,298,535 and $13,297,807 for 2000 and 2001, respectively.
Alternatively, respondent determined that in substance the two SNCB LILO
transactions were a financing arrangement and therefore increased John Hancock's
taxable income by $2,189,343 and $2,332,181 for OID income for 2000 and 2001,
respectively. Urider this alternative argument, respondent concedes John
Hancock's deductions for amortized transaction costs.
With respect to the TIWAG SILO, respondent determined that John
Hancock had not acquired the benefits and burdens of ownership of the property
subject to the SILO transaction and therefore denied John Hancock's deductions
of $807,500 for a depreciatiön expense, $535,234 for an interest expense, and
$2,802 for amortized transaction costs for 2001. Additionally, respondent
determined that in substance the John Hancock made a loan to TIWAG and failed
to report interest income on that loan. Therefore, respondent increased John
Hancock's taxable income by $78,302 for OID income for 2001.
- 75 With respect to the two Dortmund SILO transactions, respondent
determined that John Hancock had not acquired the benefits and burdens of
ownership of the property subject to the SILO transactions and therefore denied
John Hancock's deductions of $115,170 for depreciation expenses, $240,614 for
interest expenses, and $21,259 for amortized transaction costs for 2001.
Additionally, respondent determined that in substance John Hancock made a loan
to Dortmund and failed to report interest income on that loan. Therefore,
respondent increased John Hancock's taxable income by $24,985 for OID income
for 2001.
With respect to the SNCB SILO, respondent determined that John Hancock
had not acquired the benefits and burdens of ownership of the property subject to
the SILO transaction and therefore denied John Hancock's deductions of
$5,032,552 for a depreciation expense, $2,594,278 for an interest expense, and
$15,898 for amortized transaction costs for 2001. Additionally, respondent
determined that in substance the John Hancock made a loan to SNCB and failed to
report interest income on that loan. Therefore, respondent increased John
Hancock's taxable income by $627,439 for OID income for 2001.26
26Respondent made similar determinations and denied similar deductions for
the six other LILO transactions and one other SILO transaction listed in the notice
(continued...)
- 76 D.
Pretrial Motions
Respondent failed to timely raise the economic substance theory in the
pleadings, instead raising the issue for the first time in his pretrial memorandum,
dated September 16, 2011. Petitioners filed a motion in limine for exclusion of
respondent's argument based on the economic substance theory on September 23,
2011, and respondent filed an objection to petitioners' motion on October 6, 2011.
On October 11, 2011, the parties presented oral arguments to the Court with
respect to petitioners' motion. By order of the Court dated October 12, 2011, we
denied petitioners' motion in limine for exclusion of the economic substance
theory but placed the burden of proof with respect to the economic substance
theory on respondent.
II.
Trial
The Court held a five-week special trial session in Boston, Massachusetts.
The record in these cases includes the testimony of 53 witnesses, over 3,600
exhibits, over 4,000 pages of trial transcripts, and over 1,000 pages of briefing.
Both parties rely heavily on expert opinions to support their arguments. The
parties' expert witnesses, their qualifications, and their Court-recognized
26(...continued)
of deficiency.
- 77 expertises are listed below. We evaluate expert opinions in the light of all of the
evidence in the record, and we are not bound by the opinion of any expert witness.
Helvering v. Nat'l Grocery Co., 304 U.S. 282, 295 (1938); Shepherd v.
Commissioner, 115 T.C. 376 (2000), aff'd, 283 F.3d 1258 (1 lth Cir. 2002). We
may reject, in whole or in part, any expert opinion. Estate of Davis v.
Commissioner, 110 T.C. 530, 538 (1998).
A.
Petitioners' Expert Witnesses (Alphabetical Order)
1.
Mr. John Dolan
The Court recognized Mr. Dolan as an expert in the field of European
railways and railway assets. .Mr. Dolan is a chartered civil engineer, a member of
the Institution of Civil Engineers, and a holder of the title European engineer. He
is also a chartered member of the Institute of Logistics and Transport. Mr. Dolan
has worked in the European railway industry since 1972 and currently works as a
consultant for InterFleet Technology Ltd. where he advises on a range of railway
safety, infrastructure, and operational issues. He previously worked in advisory
roles for Haliburton, Her Majesty's Railway Inspectorate, and British Rail.
2.
Dr. Paul Doralt
The Court recognized Dr. Doralt as an expert in the field of Austrian tax
law. Dr. Doralt is admitted to the Austrian Chamber of Accountants as a certified
- 78 tax adviser and to the Austrian bar as an attorney. He is currently a partner at
Dorda Brugger Jordis GmbH, with his practice focus in tax law. Mr. Doralt is a
board member of the International Tax Committee of the International Bar
Association.
3.
Mr. Hans Haider
The Court recognized Mr. Haider as an expert in the field of Austrian and
European electricity. Mr. Haider is currently the managing partner of Hans Haider
Consulting. He has over 40 years of experience, having served as a member of the
management board of Siemens AG Austria and chairman of the management
board and CEO of Verbund AG, Austria's largest utility. He has previously
served as president of the Austrian National Committee to the World Energy
Counsel and president of the European Union of the Electricity Industry. Mr.
Haider is currently a member of Ernst & Young's Energy Advisory Board.
4.
Dr. Friedrich Hey
The Court recognized Dr. Hey as an expert in the field of German tax law.
Dr. Hey received a doctorate in law from the University of Hamburg/Germany and
is admitted as a certified tax adviser and a German attorney. He is currently a
partner at Debevoise & Plimpton LLP (Debevoise & Plimpton) and the chair of
the German American Lawyers Association. Dr. Hey's work has been published
- 79 numerous times, and he has been recognized as a leading German tax expert by
publications such as Chambers, Legal 500 EMEA, PLC Which Lawyer?, and
Who's Who-Legal.
5.
Dr. Friedrich Popp
The Court recognized Dr. Popp as an expert in the field of Austrian
corporate law and creditor rights law. Dr. Popp received a doctorate in law from
the University of Vienna/Austria with a thesis in civil law. He is currently an
associate at Debevoise & Plimpton. Dr. Popp has published numerous articles in
various journals and is a frequent contributor to the Austrian Journal of Banking
and Financial Research.
6.
Dr. Thomas Schurrle
The Court recognized Dr. Schurrle as an expert in the field of German
administrative and public law. Mr. Schurrle received a doctorate in law from the
University of Heidelberg. He is currently the managing partner of the Frankfurt
office of Debevoise & Plimpton. His experience has focused on advising
municipalities and companies on the financial, economic, and regulatory aspects
of cross-border leasing. Mr. Schurrle teaches a law class at the Institute of Law
and Finance at the Johann-Wolfgang-Goethe-University in Frankfurt.
- 80 7.
Dr. Norbert Stoeck
The Court recognized Dr. Stoeck as an expert in the field of trade fair
industry including the ownership and operation of trade fairs in Germany. Dr.
Stoeck received a Ph.D. in marketing from the University of Rostock. Since 1983
he has worked at Roland Berger Strategy Consultants and currently serves as the
head of the "International Trade Shows, Tourism and Mega-Events" practice
group. In this role Dr. Stoeck has managed over 100 trade fair projects
internationally and advised on countless others including trade fairs in German
municipalities. He has written numerous books and articles discussing the
management of trade fairs, trade fair strategies, and all other aspects of the trade
fair industry.
8.
Dr. Frederik Vandendriessche
The Court recognized Dr. Vandendriessche as an expert in the field of
Belgian administrative and public law. Dr. Vandendriessche received a doctorate
in law at the University of Ghent with a focus in public and private legal entities.
He is currently a partner in the Brussels office of Stibbe where he focuses his
practice in administrative law. Dr. Vandendriessche is a professor of public law at
the University of Ghent and the University of Antwerp. He has written a wide
- 81 range of articles about public law that have been published in Belgian journals and
magazmes.
B.
Respondent's Expert Witnesses (Alphabetical Order)
1.
Dr. Ignaas Behaeghe
The Court recognized Dr. Behaeghe as an expert in Belgian law. Dr.
Behaeghe received a doctorate in law and economic sciences from the University
of Antwerp and a master's in tax law from the Fiscale Hogeschool in Brussels. He
is currently an equity partner at Eversheds Brussels.
2.
Dr. Stefan Diemer
The Court recognized Dr. Diemer as an expert in the field of German tax
law. Dr. Diemer received his doctorate in law from the University of Regensburg.
He is currently a partner at Heisse Kursawe Eversheds and practices in the area of
corporate and tax law. Dr. Diemer is a certified tax lawyer and is a member of the
International Transaction Support Team of Eversheds, a unit specializing in
international transactions. The JUVE Handbuch 2009/2010 lists Dr. Diemer as a
frequently recommended lawyer in the field of corporate law.
3.
Dr. Matthias Heisse
The Court recognized Dr. Heisse as an expert in the field of German law,
except for German criminal law. Dr. Heisse received his doctorate in law from the
- 82 University of Munich. He is currently the managing partner of Heisse Kursawe
Eversheds and focuses his practice in mergers and acquisitions, corporate, and tax
law. Dr. Heisse lectures on corporate law topics at the University of Turin, the
University of Munich, and the University of Augsburg. He is recognized in
numerous publications such as Chambers Europe, Legal 500 Europe, and the
JUVE Handbook 2010/2011 as a leading attorney in the field of corporate law.
4.
Dr. Thomas Lys
The Court recognized Dr. Lys as an expert in the field of financial
economics. Dr. Lys received his Ph.D. in accounting and finance from the
University of Rochester. He presently holds the Eric L. Kohler chair in accounting
and professor of accounting and information management at the Northwestern
University Kellogg School of Professional Management. Dr. Lys teaches classes
in financial reporting, security analysis, and mergers and acquisitions. Dr. Lys'
research has been published in prominent academic journals including the Journal
of Accounting and Economics, the Journal of Financial Economics, the Journal of
Business, and the Accounting Review. Dr. Lys has previously testified for the
Government in other Federal leasing cases.
- 83 5.
Dr. F.H. Rolf Seringhaus
The Court recognized Dr. Seringhaus as an expert in the field of trade fair
exhibiting and marketing. Dr. Seringhaus earned his doctorate in administrative
studies from York University. He is a professor emeritus in global marketing at
the Wilfred Laurier University School of Business and Economics. Dr.
Seringhaus has worked in academics since 1981 teaching courses and researching
international marketing. He has written countless journal articles discussing
topics such as international trade fairs and marketing, as well as three books on
global marketing management.
6.
Mag. Alexander Stolitzka
The Court recognized Mag. Stolitzka as an expert in the field of Austrian
law. Mag. Stolitzka received a doctorate in law from Vienna University. He is
currently the managing partner of Eversheds Austria, focusing his practice in real
estate, insurance, and corporate law. He is also a member of the board of directors
of Eversheds International, Ltd., London. Mag. Stolitzka is a member of the
German Chamber of Commerce in Austria and is also a legal adviser to the Swiss
embassy in Vienna.
- 84 7.
Dr. Vukan Vuchic
The Court recognized Dr. Vuchic as an expert in the field of transportation
systems. Dr. Vuchic received a Ph.D. in civil engineering and transportation from
the University of California at Berkeley. He is an emeritus professor of
transportation systems engineering at the University of Pennsylvania where he
taught and performed research in various areas of transportation from 1967-2010.
Dr. Vuchic has written over 150 papers and reports discussing rail systems and has
lectured at approximately 90 universities. He has also published three books on
urban public transportation systems and another book on relationship of
transportation and cities. Dr. Vuchic is also the recipient of numerous honors and
awards from transportation organizations around the world for his contributions to
the field of transportation systems.
8.
Dr. Peter Wundsam
The Court recognized Dr. Wundsam as an expert in the field of Austrian
taxation and accounting. Dr. Wundsam is a partner at Moore Stephens in Vienna
and has been working as an auditor and tax consultant for 15 years. He is a
certified public accountant and certified tax adviser in Austria. He is also a
member of the executive board of the Chamber of Accountants and a member of
the committee on commercial law and auditing within the Austrian Chamber of
- 85 Accountants. Further, Dr. Windsam is the head of the working committee public
sector of the Austrian Institute of Auditors and an editor of the publication Public
Sector Bulletin.
OPINION
Burden of Proof
The burden is upon petitioners to prove that respondent's determinations in
the notices of deficiency are incorrect. See Rule 142(a)(1). However, in respect
of any new matter, respondent bears the burden of proof. Id. Respondent failed to
timely raise his economic substance argument in the pleadings. As a result, on
October 12, 2011, the Court issued an order placing the burden in these cases on
respondent to prove that the economic substance doctrine applies to the leveraged
leases. Petitioners do not argue that the burden of proof shifts to respondent
pursuant to section 7491(a) for any other issue or year, nor have they shown that
the threshold requirements of section 7491(a) have been met for any of the other
determinations at issue. Accordingly, the burden remains on petitioners with
respect to all other issues to prove that respondent's determinations of deficiencies
in income tax are incorrect.
- 86 Principal Place of Business
In the case at docket No. 7083-10 the parties disagree as to whether an
appeal would come before the U.S. Court of Appeals for the First or Sixth Circuit.
In the case of a corporation seeking redetermination of a tax liability, section
7482(b)(1)(B) provides that a decision of the Tax Court "may be reviewed by the
United States court of appeals for the circuit in which is located * * * the principal
place of business or principal office or agency of the corporation". This
determination is made as of the time the petition is filed. Thus, the crux of the
parties' dispute is the location of MIC's "principal place of business".
The Supreme Court has recently determined that a corporation's "principal
place of business" is "best read as referring to the place where a corporation's
officers direct, control, and coordinate the corporation's activities." Hertz Corp. v.
Friend, 559 U.S. 77, 92-93 (2010). This is often referred to as the "nerve center"
test, and it normally refers to where a corporation maintains its headquarters,
provided that the headquarters is the actual center of direction, control and
coordination. Id. Respondent argues that MIC's principal place of business is and
always has been in Michigan because MIC was incorporated there and has
represented in correspondence to the IRS and the Michigan Department of
Consumer & Industry Services that its principal place of business is in Michigan.
- 87 Petitioners argue, on the other hand, that MIC's principal place of business is in
Massachusetts because six of its nine corporate officers" and all three of its
directors work in Massachusetts, its corporate books and records are kept in
Massachusetts, and its significant business decisions have been and continue to be
made in Massachusetts. Further, MIC does not maintain offices in Michigan.
It is clear to us that MIC's "nerve center" is in Massachusetts. Respondent
has not presented any evidence to dispute that MIC's office in Massachusetts is
the center of its direction, control, and coordination. Therefore, we conclude that
Massachusetts was MIC's principal place of business when its petition was filed.
Leveraged Lease Transactions
I.
Frank Lyon Co. v. United States
The seminal case for leveraged lease transactions is Frank Lyon Co. v.
United States, 435 U.S. 561 (1978), where the Supreme Court set forth the
circumstances under which the Commissioner must respect such a transaction for
Federal tax purposes. The Supreme Court stated:
where * * * there is a genuine multiple-party transaction with
economic substance which is compelled or encouraged by business or
regulatory realities, that is imbued with tax-independent
considerations, and that is not shaped solely by tax-avoidance
The remaining three officers work in Toronto, Canada.
- 88 features * * * [to which] meaningless labels [are] attached, the
Government should honor the allocation of rights and
duties effectuated by the parties. Expressed another way, so long as
the lessor retains significant and genuine attributes of the traditional
lessor status, the form of the transaction adopted by the parties
governs for tax purposes. What those attributes are in any particular
case will necessarily depend upon its facts. * * * [Id. at 583-584; fn.
ref. omitted.]
In Frank Lyon, Worthen Bank (Worthen) sought to construct a new bank
building. State and Federal regulations prohibited Worthen from financing the
construction through conventional methods. As a result, Worthen was forced to
find alternative financing, and eventually came to an agreement with the taxpayer,
Frank Lyon Co. (Frank Lyon). Pursuant to this agreement, Frank Lyon purchased
the building from Worthen during its construction for a total of $7,640,000, and
leased it back to Worthen for an initial term of 25 years. Frank Lyon invested
$500,000 and financed the remainder with a third-party lender. A mortgage
secured the loan on the building, as well as Frank Lyon's promise to assume
personal responsibility for the loan's repayment and an assignment to the lender of
the rental payments under the lease.
Worthen retained options to repurchase the building at the end of the 11th,
15th, 20th, and 25th years of the initial lease. Alternatively, Worthen could opt to
renew the lease for eight additional five-year terms. Worthen's rent payments
- 89 equaled the amounts of Frank Lyon's debt service in amount and timing. Further,
the prices of Worthen's purchase options matched Frank Lyon's then-outstanding
loan balance, plus Frank Lyon's initial $500,000 investment, with 6%
compounded interest. The lease was a net lease with Worthen remaining obligated
to pay taxes, insurance, and utilities.
The Supreme Court held that the form of a sale-leaseback transaction will
be respected for Federal tax purposes as long as the taxpayer retains significant
and genuine attributes of a traditional lessor. Id. at 584. An important inquiry is
"whose capital was committed to the * * * [property] * * * [and therefore, who is]
entitled to claim depreciation for the consumption of that capital." Id. at 581.
Frank Lyon was liable as principal for the repayment of the $7,640,000 loan, had
invested $500,000 in the transaction, and its return on the transaction was
guaranteed only if Worthen exercised its extension options, which was
speculative.
The Supreme Court also determined the following factors, among others, to
favor Frank Lyon: (1) Worthen's rent and purchase option prices were reasonable;
(2) Frank Lyon assumed the credit risk of Worthen's defaulting on its rent
payments; (3) there was a real possibility that Worthen could walk away from the
transaction at the end of the initial lease; (4) the transaction was negotiated in
- 90 good faith between independent parties; and (5) Worthen and Frank Lyon paid the
same tax rates, making the transaction tax neutral for the fisc. Accordingly, the
Supreme Court held for Frank Lyon, concluding that "a sale-and-leaseback, in and
of itself, does not necessarily operate to deny a taxpayer's claim for deductions."
Frank Lyon, 435 U.S. at 584.
A.
Economic Substance
After the Supreme Court issued its opinion in Frank Lyon, several Courts of
Appeals reduced the Supreme Court's economic substance formulation to a twopart test: (1) whether the transaction had economic substance beyond tax benefits
(objective test); and (2) whether the taxpayer had shown a nontax business
purpose for entering the disputed transaction (subjective test). See, e.g., ACM
P'ship v. Commissioner, 157 F.3d 231, 247-248 (3d Cir. 1998), aff'g in part, rev'a
in part T.C. Memo. 1997-115; Bail Bonds by Marvin Nelson, Inc. v.
Commissioner, 820 F.2d 1543, 1549 (9th Cir. 1987), aff'g T.C. Memo. 1986-23;
Rice's Toyota World, Inc. v. Commissioner, 752 F.2d 89, 91-92 (4th Cir. 1985),
aff'g in part, rev'g in part 81 T.C. 184 (1983). However, the various Courts of
- 91 Appeals disagree as to the appropriate relationship between the objective and
subjective tests.28
The Court of Appeals for the Fourth Circuit has adopted a disjunctive
approach, treating a transaction as having economic substance if the transaction
has either a business purpose or economic substance. See, e.g., Rice's Toyota
World, Inc. v. Commissioner, 752 F.2d at 91-92. The Courts of Appeals for the
Ninth and Eleventh Circuits view the objective and subjective prongs as elements
of one comprehensive inquiry. See, e.g., Sacks v. Commissioner, 69 F.3d 982,
988 (9th Cir. 1995), rev'g T.C. Memo.1992-596; Kirchman v. Commissioner, 862
F.2d 1486, 1492 (11th Cir.1989), affg Glass v. Commissioner, 87 T.C. 1087
(1986). Finally, the Court of Appeals for the Federal Circuit adheres to a
multifactor test which provides that a lack of economic substance may be
sufficient to invalidate a transaction regardless of whether the taxpayer has
motives other than tax avoidance. Coltec Indus., Inc. v. United States, 454 F.3d
1340, 1355 (Fed. Cir. 2006).
28Congress codified the economic substance doctrine in the Code by the
Health Care and Education Reconciliation Act of 2010, Pub. L. No. 111-152, sec.
1409, 124 Stat. at 1067. See also H.R. Rept. No. 111-443 (I), at 291-299 (2010),
2010 U.S.C.C.A.N. 123, 222-231 (discussing the reasons for codification of the
economic substance doctrine). This codified doctrine does not apply to these
cases because it is effective only for transactions entered into after March 30,
2010.
- 92 B.
Substance Over Form
Courts use substance over form and its related judicial doctrines to
determine the true nature of a transaction disguised by formalisms that exist solely
to alter tax liabilities. See United States v. R.F. Ball Constr. Co., 355 U.S. 587
(1958); Commissioner v. Court Holding Co., 324 U.S. 331 (1945); Stewart v.
Commissioner, 714 F.2d 977, 987-988 (9th Cir. 1983), a_[f'g T.C. Memo.
1982-209; Rose v. Commissioner, T.C. Memo. 1973-207. In such instances, the
substance of a transaction, rather than its form, will be given effect. We generally
respect the form of a transaction, however, and will apply the substance over form
principles only when warranted. See Gregory v. Helvering, 293 U.S. 465 (1935);
Blueberry Land Co. v. Commissioner, 361 F.2d 93, 100-101 (5th Cir. 1966), aff'g
42 T.C. 1137 (1964).
In Frank Lyon, 435 U.S. at 584, the Supreme Court held that the form of a
sale-leaseback transaction will be respected for Federal tax purposes as long as the
lessor retains significant and genuine attributes of a traditional lessor. The
substance over form doctrine requires viewing the transaction as a whole.
Commissioner v. Court Holding Co., 324 U.S. at 334. A "critical fact," however,
is whether the taxpayer has undertaken "substantial financial risk" of loss of its
investment on the basis of the value of the underlying property. Coleman v.
- 93 Commissioner, 16 F.3d 821, 826 (7th Cir. 1994), aff'g T.C. Memo. 1987-195 and
T.C. Memo. 1990-99.
II.
LILO and SILO Litigation
In the case at bar, petitioners assert that the LILO and SILO leveraged
leases are genuine multiple-party transactions, with economic substance, that were
compelled or encouraged by business realities and were not designed as a scheme
to avoid payment of taxes. As such, petitioners assert, the LILO and SILO
leveraged leases should be respected for Federal tax purposes because they satisfy
the requirements set out by the Supreme Court in Frank Lyon Co.
Respondent contends that the LILO and SILO leveraged leases are
"prepackaged, promoted tax products" that "create tax benefits for John Hancock
out of thin air, and share that value with the counterparties, promoters, and
advisors". Therefore, respondent argues that the leveraged leases should not be
respected for Federal tax purposes because John Hancock did not acquire the
benefits and burdens of ownership with respect to the SILO transactions or a true
leasehold interest with respect to the LILO transactions and thus the transactions
lack economic substance.
Taxpayers have lost their fight for claimed tax benefits in SILO and LILO
transactions in all Courts of Appeals in which they have appeared. The Courts of
- 94 -
Appeals for the Second and Fourth Circuits have ruled against taxpayers in Altria
Grp., Inc. v. United States, 658 F.3d 276 (2d Cir. 2011) (denying the taxpayer's
motion for judgment as a matter of law and a new trial after a jury verdict
disallowed the tax benefits derived from three SILO transactions and a LILO
transaction), aff'g 694 F. Supp. 2d 259 (S.D.N.Y.2010), and BB&T Corp. v.
United States, 523 F.3d 461 (4th Cir. 2008) (disallowing the tax benefits derived
from a LILO transaction), a_ffEg 2007 WL 37798 (M.D.N.C. 2007), respectively.
Likewise, the Court of Appeals for the Federal Circuit has ruled against taxpayers
in Wells Fargo & Co. v. United States, 641 F.3d 1319 (Fed. Cir. 2011)
(disallowing the tax benefits derived from 26 SILO transactions), afEg 91 Fed. Cl.
35 (2010), and Consol. Edison Co. of N.Y., Inc. & Subs. v. United States, 703
F.3d 1367, 2013 WL 93110 (Fed. Cir. 2013) (disallowing tax benefits derived
from a LILO transaction because the taxpayer never acquired the benefits and
burdens of ownership), rev'g 90 Fed. Cl. 228 (2009). In AWG Leasing Trust v.
United States, 592 F. Supp. 2d 953 (N.D. Ohio 2008), the District Court for the
Northern District of Ohio disallowed the tax benefits derived from a SILO
transaction. AWG was not appealed.29
29Additionally, in Fifth Third Bancorp v. United States, No. 05-350 (S.D.
Ohio Apr. 18, 2008), a jury verdict without a related published opinion disallowed
(continued...)
- 95 The Tax Court has never ruled upon the income tax consequences of a LILO
or SILO transaction. As an aid to our evaluation of the present case, we will
review the LILO and SILO cases already decided, in chronological order by the
date they were decided. We begin with BB&T, in which the Court of Appeals for
the Fourth Circuit established the basis for a substance over form inquiry with
respect to LILO transactions. We next review AWG, in which the District Court
for the Northern District of Ohio was the first court to review a SILO transaction,
applying both a substance over form inquiry and a two-part economic substance
inquiry. Finally, we review three decisions from the Courts of Appeals for the
Second Circuit3° and the Federal Circuit," which determine whether the substance
of each transaction is consistent with its form, among other inquiries, and set forth
29(...Continued)
the taxpayer's claimed tax benefits derived from a LILO transaction. Further,
beginning on March 12, 2012, the Court of Federal Claims held a 10-day trial in
Unionbancal Co. & Subs. v. United States, No. 1:06-cv-00587 (Fed. Cl. filed Aug.
14, 2006), to determine whether to uphold assessed deficiencies resulting from
two LILO transactions. To date, no opinion has been issued and no decision has
been rendered in that case.
3°Altria Grp., Inc. v. United States, 658 F.3d 276 (2d Cir. 2011), aff'g 694 F.
Supp 2d. 259 (S.D.N.Y. 2010).
Wells Fargo & Co. v. United States, 641 F.3d 1319 (Fed. Cir. 2011), aff'g
91 Fed. Cl. 35 (2010), and Consol. Edison Co. of N.Y., Inc. & Subs. v. United
States, 703 F.3d 1367 (Fed. Cir. 2013), rev'g 90 Fed. Cl. 228 (2009).
- 96 the standard by which to judge whether a purchase option is likely to be exercised
in a LILO or SILO transaction.
A.
BB&T
In the first case of its kind, the Court of Appeals for the Fourth Circuit
affirmed a District Court's decision to grant summary judgment to the
Government, disallowing the taxpayer's claimed deductions in connection with a
LILO transaction. BB&T, 523 F.3d 461. The taxpayer, BB&T Corp. (BB&T),
was a domestic financial service company. In the LILO transaction, BB&T leased
pulp manufacturing equipment from Sodra Cell AB (Sodra), a Swedish
manufacturer of wood pulp, for a term of 36 years and subleased the equipment
back to Sodra for a term of 15.5 years.
BB&T's LILO transaction was very similar to the typical LILO transaction
described above in section IV.A of our findings of fact and depicted in the
associated graphic. The rights and obligations conferred in the initial lease and
sublease were nearly identical, with Sodra continuing to use and possess the
equipment as it did before the transaction. The transaction was fully defeased,
resulting in a series of bookkeeping entries in satisfaction of Sodra's sublease rent
payments and BB&T's debt service which matched in amount and timing. The
defeasance transactions also prefunded Sodra's purchase option at the end of the
- 97 sublease. As in John Hancock's LILO transactions, if Sodra were to decide not to
exercise its purchase option, BB&T would have the choice of: (1) renewing the
sublease; (2) replacing Sodra; or (3) retaining the equipment. Finally, Sodra was
required to procure a long-term letter of credit for the benefit of BB&T in the
event that the transaction was unwound early.
BB&T argued to the District Court that it had acquired a legitimate
leasehold interest in the equipment. The argument was predicated upon certain
new obligations imposed on Sodra as part of the sublease, including Sodra's
obligation to maintain and operate the equipment consistently with certain
standards, hold a specified amount of insurance, and file certain reports not
previously required. The court disagreed, holding that "[i]n substance, Sodra's use
and possession of the [e]quipment was unaltered by the transaction". The court
held that nothing in the record indicated that any alterations to Sodra's rights and
obligations with respect to the equipment were unique to the initial lease, nor was
there any evidence that such obligations were not the responsibility of Sodra
before the LILO transaction.
The District Court further held that even if Sodra were to choose not to
exercise its purchase option, the defeasance structures and obligations imposed on
the parties ensured that BB&T bore no real risk of loss. Despite construing the
- 98 evidence in the light most favorable to BB&T, the court granted the Government's
motion for summary judgment, disregarded the reciprocal and offsetting
obligations of the LILO transaction, and concluded that BB&T acquired no more
than a future interest in the equipment.
On appeal, the Court of Appeals for the Fourth Circuit affirmed the trial
court's decision. Applying the doctrine of substance over form, the Court of
Appeals determined that in order for BB&T to deduct payment on the initial lease
as a rent payment under section 162(a)(3), it had to establish that it acquired a
genuine leasehold interest in the equipment, i.e., that the initial lease was, in
substance, a true lease for tax purposes.
In determining whether the transaction allocated BB&T's and Sodra's
rights, obligations, and risks in a manner that resembles a traditional lease
relationship, the court found that (1) BB&T and Sodra exchanged nearly identical
rights and obligations in the initial lease and sublease, leav.ing BB&T only a right
to make an annual inspection of the equipment; (2) though the transaction
provided for the exchange of tens of millions of dollars in rent payments, there
was a lack of actual cashflow during the term of the transaction aside from the
money BB&T provided Sodra as incentive for the transaction; (3) Sodra, through
its purchase option, could unwind the transaction without ever losing dominion
- 99 and control over the equipment or having surrendered any of its own funds to
BB&T and had no economic incentive to do otherwise; thus, BB&T did not expect
Sodra to walk away from the cashless purchase option at the end of the sublease;
and (4) the structure insulated BB&T from any risk of losing its initial investment.
BB&T, 523 F.3d at 473.
Moreover, the court held that unlike the transaction in Frank Lyon, the
LILO transaction "failed to show any 'business or regulatory realities' that
'compelled or encouraged * * * the structure of the transaction at issue here, nor
has it established that the LILO is 'imbued with tax-independent considerations,
and is not shaped solely by tax avoidance features that have meaningless labels
attached'". Id. Thus, the court held in substance the transaction was a financing
arrangement, not a genuine lease and sublease.
The court did not analyze BB&T's LILO transaction for economic
substance. The court noted that whether a particular transaction lacks economic
substance is a question of fact. Id. at 472. As a result, because the case arose out
of a motion for summary judgment, the District Court and Court of Appeals were
required to view the facts in a light most favorable to BB&T, and both courts
assumed the LILO transaction had economic substance.
- 100 B.
AWG
In AWG, 592 F. Supp. 2d 953, the District Court for the Northern District of
Ohio was the first court to review a SILO transaction. In the transaction at issue,
KeyCorp (Key) and PNC Financial Services Group, Inc. (PNC), two financial
institutions, entered into a grantor trust (Key/PNC). Key/PNC leased a waste-to-
energy disposal and treatment plant (facility) in Wuppertal, Germany, from
Abfallwirtschaftgesellschaft mbH Wuppertal (AWG) for a term of 75 years and
subleased the facility back to AWG for a term of 24 years. A consortium of
German municipalities owned AWG, and they were also some of the facility's
most important customers. Like John Hancock's SILO transactions, because the
initial lease exceeded the expected economic useful life of the leased asset, it was
treated as a sale for U.S. Federal tax purposes.
The sublease was a net lease, with AWG retaining nearly identical rights
and obligations with respect to the facility as it had before the SILO transaction.
Key/PNC through an equity contribution provided approximately 13% of the
prepaid rent to AWG as required by the initial lease. Similar to John Hancock's
SILO transactions, the remainder of the transaction was financed through two
nonrecourse loans, a series A loan accounting for 90% of the debt and a series B
loan accounting for the remaining 10%. Unlike John Hancock's SILO
- 101 transactions, Key/PNC required that the transaction feature full defeasance, with
AWG obligated to enter into separate DPUAs for the series A and series B loans,
as well as an EPUA. These defeasance agreements ensured the payment of
AWG's rental obligation under the sublease, which matched Key/PNC's debt
service in amount and timing, and funded AWG's purchase option. The series A
DPUA was pledged as collateral for repayment of Key/PNC's loans.
The structure of AWG's purchase option was similar to those of the lessee
counterparties in John Hancock's SILO transactions. However, unlike John
Hancock's SILO transactions, if AWG chose not to exercise its purchase option,
Key/PNC was not given options. Rather, the transaction required AWG to enter
into a service contract to purchase solid waste disposal services from Key/PNC for
a specified term. As in John Hancock's SILO transactions, the service contract
option required the lessee counterparty, AWG, to arrange for a refmancing of
Key/PNC's nonrecourse debt.
In order to determine whether Key/PNC was entitled to the claimed tax
deductions, the District Court analyzed the economic substance of the transaction
following Dow Chem. Co. v. United States, 435 F.3d 594, 599 (6th Cir. 2006),
which treats a transaction as having economic substance only if the transaction has
- 102 genuine economic effects other than tax benefits and the taxpayer is truly
motivated by profit to participate in the transaction.
Starting with the assumption that AWG would exercise its purchase option,
the evidence showed that Key/PNC would receive approximately $78 million on
its $55 million equity investment during the sublease term. The court held that
this 3.4% return was consistent with the type of return banks ordinarily receive
from leveraged lease transactions. Further, the court held that although it was
unlikely that AWG would choose the service contract option, if it did so Key/PNC
had the potential to earn between 5% and 8% on its equity investment, depending
on the facility's business production. Accordingly, the District Court held that the
transaction had genuine economic effects other than tax benefits. The court also
held that Key/PNC had a profit motive, relying on the small chance that the
transaction could earn between 5% and 8%.
Having concluded that the SILO transaction had economic substance, the
District Court turned to the substance over form test. Citing Frank Lyon, 453 U.S.
561, the District Court held that in order for Key/PNC to prevail on its claim that
the substance of the transaction was consistent with its form, thus entitling
Key/PNC to tax depreciation and amortization deductions, Key/PNC had to prove
that it both obtained and kept significant and genuine characteristics of ownership
- 103 of the facility. "Such genuine attributes of ownership are generally found only
where the alleged owner bears both the burdens and enjoys the benefits of asset
ownership." AWG, 592 F. Supp. 2d at 981.
Several facts were pivotal to the court's decision. First, the court held that
AWG's rights and obligations with respect to the facility remained virtually the
same before and after the SILO transaction. Notably, under German law, legal
title to the facility remained with AWG, entitling AWG to depreciation deductions
on the facility for German tax purposes. Next, the court pointed to the circular
nature of the SILO transaction's payment structure, holding that the offsetting
payments strongly indicated that the transaction had little substantive purpose.
Third, the court held that Key/PNC did not assume the substantive credit, residual
value, or remarketing risk that is typical of a lessor in a leveraged lease. Aside
from its other protections, the court noted that the SILO transaction included a
guaranty from the municipal members of AWG, backed by the German Federal
Government, to the benefit of Key/PNC.
Finally, the District Court emphasized that AWG was "highly likely" or
"nearly certain"" to exercise its purchase option. If AWG did not exercise the
"The District Court also used terms such as "compelled to" and "virtually
certain" to determine whether AWG would exercise its purchase option. AWG
(continued...)
-104purchase option, it was required to refinance Key/PNC's nonrecourse debt of $383
million. On the purchase option date, the appraisal estimated the fair market value
of the facility to be $390 million. Accordingly, initial refinancing would require a
loan-to-value ratio of over 98%. A provision in the service contract required a $50
million payment from AWG, reducing the amount required to be borrowed to $333
million. Nonetheless, this loan-to-value ratio of approximately 85% was still well
above the typical ratio for a Gennan loan, of no greater than 67%. The District
Court concluded that exercise of the purchase option was the only viable choice .
for AWG.
The court also took into consideration the tax consequence to AWG of
nonexercise under German law. As is the case in John Hancock's SILO
transactions, although the initial lease is treated as a sale for U.S. Federal tax
purposes, under German law AWG remained the owner of the facility. If AWG
were to elect the service contract option, it would receive the cash balance from
"(...continued)
Leasing Trust v. United States, 592 F. Supp. 2d 953, 986 (N.D. Ohio 2008). Later,
Courts of Appeals have discussed in depth the standard to be used to determine
whether a party in a SILO or LILO transaction will exercise its purchase option.
See Wells Fargo, 641 F.3d at 1325-1330; Consol. Edison, 703 F.3d at 1379. The
District Court in AWG lacked the benefit of the Court of Appeals for the Federal
Circuit's in-depth analysis of the issue and creation of a reasonable likelihood
standard.
- 105 the DPUAs and EPUA, or approximately $521 million. The District Court held
that this receipt of cash, combined with AWG's relinquishment of the facility,
would likely be treated as a taxable sale under German law. The transaction's
original appraisal failed to consider this possibility and its impact on AWG's
purchase option decision.
Several other unique facts were important in the District Court's decision.
For instance, the court seemed skeptical about the accuracy of the appraisal,
pointing to the large discrepancy between the facility's original appraised fair
market value of $250 million and the $450 million appraisal used to build the
transaction. The court also noted that no representative from AWG testified at
trial to provide evidence of any reason for AWG to participate in the SILO
transaction outside of its net present value benefit. In sum, the court concluded
that
the AWG transaction is a financing arrangement designed in
significant measure to increase tax deductions available to * * *
[Key/PNC]. The AWG transaction * * * is not a genuine sale and
leaseback. Essentially all that * * * [Key/PNC] did was to pay AWG
a $28.5 million accommodation fee to sign paperwork meeting the
formal requirements of a sale and leaseback and to arrange a circular
and largely meaningless flow of cash from and then back to * * * [the
German lenders]. AWG, meanwhile, continues to have undisturbed
and uninterrupted possession and control of the Facility, continues to
claim the tax benefits of ownership of the Facility under German law,
and has no economic or political motivation to give up control of the
- 106 plant to * * * [Key/PNC] at any time. Because * * * [Key/PNC]
never became the true owners of the Facility, they are not entitled to
deductions for the depreciation or amortization of expenses
associated with the asset. [AWG, 592 F. Supp. 2d at 990.]
C.
Wells Fargo
In Wells Fargo, 641 F.3d 1319, the Court of Appeals for the Federal Circuit
affirmed the Court of Federal Claims' decision to disallow the taxpayer's claimed
tax benefits arising from 26 SILO transactions. The parties agreed to try a set of
test transactions, four of which involved transportation assets with domestic transit
agencies as the counterparties (transit agency transactions) and a fifth involving
qualified technological equipment with a foreign counterparty. The lessee
counterparties and the assets of the Wells Fargo test transactions were as follows:
(1)
New Jersey Transit Corporation--45 light rail vehicles and 650 buses;
(2)
State of California Department of Transportation (Caltrans)--6
locomotives and 12 intercity passenger rail cars;
(3)
Metropolitan Transit Authority of Harris County, Texas (Houston
Metro)--45 commuter buses and 241 transit buses;
(4)
Washington Metropolitan Area Transit Authority (WMATA)--42
subway cars; and
- 107 (5)
Belgacom Mobile, S.A., a Belgian entity (Belgacom)-2 lots of GSM
cellular communications equipment.
Wells Fargo & Co. (Wells Fargo) is a diversified financial services
company. It operates a leasing company, maintains a fairly significant leasing
portfolio, and invests in leases involving a variety of assets. Wells Fargo
conducted extensive due diligence before entering into its SILO transactions,
including credit approvals and tax capacity analyses. It also relied upon the work
of qualified appraisers, accountants, and lawyers who reviewed and provided
support for their SILO transactions.
In each of the transit agency transactions Wells Fargo, through a grantor
trust, made an initial equity contribution of approximately 15% to 20% of the
prepaid rent made to the lessee counterparty and borrowed the remainder on a
nonrecourse basis. Unlike John Hancock's SILO transactions, Wells Fargo did
not divide its borrowing into series A and series B loans. A promoter secured the
appraisals that determined the value of each transaction. The rights and
obligations transferred to Wells Fargo under the initial lease in each of the
transactions were substantially similar to those transferred back to the lessee
counterparties in the respective subleases. The lessee counterparties' rent
payments under the subleases exactly matched Wells Fargo's debt service
- 108 payments in amount and timing. Further, unlike John Hancock's SILO
transactions, which did not require series B debt or equity defeasance, each of
Wells Fargo's transactions required full debt and equity defeasance.
Wells Fargo's SILO transactions featured purchase options for the lessee
counterparties at the end of the sublease terms. The purchase options were
prefunded through the defeasance transactions. If a lessee counterparty were to
decide not to exercise its purchase option, Wells Fargo would have the choice of
either taking possession of the transportation equipment or requiring the lessee to
arrange for a service contract.
The service contract option imposed certain obligations on the lessee
counterparty. These obligations included: (1) finding an acceptable operator for
the transportation equipment and negotiating an operating agreement; (2)
arranging for the refinancing of Wells Fargo's nonrecourse loan; (3) in the
Caltrans and WMATA transactions, obtaining and paying for a letter of credit for
the benefit of the refinancing lender; (4) in the Caltrans, WMATA, and Houston
Metro transactions, procuring and paying for residual value insurance for the
benefit of Wells Fargo; (5) satisfying the equipment's physical return conditions;
and (6) if Wells Fargo requires, entering into new defeasance agreements to secure
amounts owed to Wells Fargo under the service contracts.
- 109 The trial court analyzed Wells Fargo's test transactions under both the
substance over form and economic substance doctrines. In each test transaction,
the court concluded that Wells Fargo was not entitled to its claimed deductions.
Analyzing whether the benefits and burdens of ownership had passed to Wells
Fargo, the court compared each Wells Fargo test transaction with the transaction
in Frank Lyon, finding:
The loan proceeds were not invested in the property or equipment, or
retained by either the tax-exempt entity or Wells Fargo. Moreover,
the debt and equity undertaking payment arrangements eliminated the
need for the tax-exempt entity to actually pay rent under the
lease-backs, or for Wells Fargo to actually make any debt service
payments. The "rent" and "debt" payments in each SILO simply are
accounted for as offsetting entries within the lender group. The debt
will be completely paid without Wells Fargo having to supply any
funds, whether the * * * [purchase options] are exercised or not. In
contrast, in Frank Lyon, the taxpayer alone was liable for repayment
of recourse debt, "to which it exposed its very business well-being."
* * * The taxpayer also was dependent upon the lessee for payment of
rent to service the debt. [Wells Fargo, 91 Fed. Cl. at 77.]
The court also found that Wells Fargo's return on its investment was guaranteed in
each of the SILO transactions, regardless of any decline in the value of the leased
assets.
The court distinguished Wells Fargo's test transactions "from Frank Lyon,
where the lessee had renewal options, but the exercise of the options was at the
lessee's unconstrained choice, and the taxpayer did not have the ability to impose
- 110 a renewal upon the lessee." Id. at 78. The court concluded that despite
convincing evidence that the service contract and return options were viable,
"[t]he near certain exercise of * * * [the purchase options] at the end of the leaseback period renders moot what might or might not happen after the * * *
[purchaser option] date passes." Id. at 74.
Finally, the court determined that Wells Fargo's transactions lacked
economic substance because on a net present value basis each SILO is "a losing
proposition without the tax benefits." Id. at 82. The court also held that there was
no nontax business purpose to the SILO transactions and that the transactions were
not the product of "any negotiations or commercial realities".
On appeal, Wells Fargo challenged the Court of Federal Claims' decision
with respect to both the application of the substance over form doctrine and the
court's determination that there was no economic substance. The Court of
Appeals for the Federal Circuit focused its analysis on the substance over form
inquiry (i.e., whether Wells Fargo acquired the benefits and burdens of ownership
in the leased assets) and the question of whether the lessee counterparties would
exercise their purchase options at the end of the lease term. Wells Fargo, 641 F.3d
at 1325-1330.
-111Wells Fargo argued that (at the time the transactions were entered into) it
could not know for certain whether the lessee counterparties would exercise their
purchase options. The court stated: "We have never held that the likelihood of a
particular outcome in a business transaction must be absolutely certain before
determining whether the transaction constitutes an abuse of the tax system. The
appropriate inquiry is whether a prudent investor in the taxpayer's position would
have reasonably expected * * * [the counterparties to exercise their purchase
option]", not whether the taxpayer was certain of such an outcome. Id. at 1325-
1326.
Wells Fargo challenged the testimony of Dr. Lys, the Government's expert
on financial economics, and defended its own appraisers' analyses. The court
identified the discount rate that the lessee counterparties would apply in
calculating the net present value of its purchase option decision as the "crux of the
disagreement" between Dr. Lys' analysis and those of Wells Fargo's appraisers.
The appraisers analyses used the weighted average cost of capital (WACC) in the
transit industry as the appropriate discount rate. Dr. Lys, on the other hand, used a
lower discount rate in the same way as he has done for John Hancock's
transactions, equal to the rate at which the lessee counterparty could borrow funds.
Using the borrowing rate, Dr. Lys projected that (1) the fair market values of the
- 112 leased assets on the sublease purchase options dates and (2) the cost of the
payments to Wells Fargo under the service contracts were higher than their
appraised values. As a result, Dr. Lys concluded that the service contract provided
the lessee counterparties with less financial benefit than if they simply decided to
exercise the purchase option. Wells Fargo argued that Dr. Lys' deviation from the
use of the WACC rate was inappropriate and produced inaccurate results.
The court adopted Dr. Lys' approach, citing the trial court's acceptance of
his methodology. The court declined to pass judgment on whether a different
discount rate was more appropriate. Rather, the court held that the discount rate
was a "distinctly factual matter" and that Wells Fargo had failed to prove that the
trial court's acceptance of Dr. Lys' methodology was clear error. Further, the
court concluded that the trial court's conclusion that the lessee counterparties
would exercise their purchase options did not depend on Dr. Lys' analysis. Citing
witness testimony and documentary evidence, the court held that the trial court's
findings of fact provided ample evidence that there were substantial difficulties for
the lessee counterparties to comply with the service contract option and that Wells
Fargo reasonably expected the purchase options to be exercised. Any testimony or
evidence to the contrary was "not enough to call into question" the trial court's
conclusions. Therefore, the benefits and burdens of ownership did not pass to
- 113 Wells Fargo and Wells Fargo's SILO transactions could not be respected for
Federal tax purposes under the substance over form doctrine.
D.
Altria
In Altria, 658 F.3d 276, the Court of Appeals for the Second Circuit
affirmed a District Court's decision to deny the taxpayer judgment as a matter of
law following an unfavorable jury verdict. At issue in Altria were three SILO
transactions and a LILO transaction. The taxpayer, Altria Group, Inc. (Altria), is a
financial services company. The lessee counterparties and subject assets of
Altria's test transactions were as follows:
(1)
New York Metropolitan Transportation Agency (MTA)--a rail car
maintenance facility;
(2)
Oglethorpe Power Corp. (Oglethorpe)--a pumped storage
hydroelectric facility;
(3)
Seminole Electrical Cooperative, Inc. (Seminole)--a coal-fired
electrical generating plant; and
(4)
Watershap Vallei en Eem (Vallei), an independent agency of the
Government of the Netherlands--a wastewater treatment facility. Oglethorpe,
Seminole and Vallei were SILO transactions, and MTA was a LILO transaction.
- 114 Each of Altria's transactions featured full defeasance, a lessee purchase
option, and a renewal option or service contract option at the end of the sublease
term. Additionally, in each of the transactions at issue: (1) there was no viable
secondary market for the subject assets; (2) the assets were essential to the lessee
counterparties' businesses; (3) the appraisals did not properly estimate the assets'
expected residual value and useful lives; (4) the transactions shifted tax benefits
from a nontaxable to a taxable entity, rather then transferring benefits among
taxable entities; and (5) the defeasance accounts created a circular flow of money.
Altria's motion for judgment as a matter of law argued that the jury gave
undue weight to evidence that had no bearing on the interests Altria acquired in
the transactions, that the trial court's jury instructions were misleading, and that
Altria proved that the transactions were reasonably expected to generate a non-taxbased profit. Notably, Altria argued that the jury was not instructed to consider
the proper factors in determining whether Altria acquired the benefits and burdens
of a traditional lessor.
The jury instructions asked the jury to consider "all the relevant facts and
circumstances", including the following eight nonexclusive factors: (1) whether
"meaningful" control over the assets was transferred; (2) whether the equity
investment in the facility was "meaningful"; (3) cashflows between the parties; (4)
- 115 whether the transaction was motivated by "legitimate business purposes, or solely
by a desire to create tax benefits"; (5) regulatory realities; (6) whether the assets
had expected useful lives beyond the leaseback that Altria could benefit from; (7)
whether it was reasonable to expect that the assets would have meaningful value at
the end of the leaseback which would benefit Altria; and (8) whether Altria had
the potential to benefit from an increase in the asset's value and suffer a loss of its
equity investment in the facility as a result of a decrease in the facility's value.
Altria, 694 F. Supp. 2d at 271. For factors 6-8, the District Court asked the jury to
consider the "likelihood" that the lessee counterparty would exercise its purchase
option.
Altria argued that these factors were inappropriate, that the controlling
factors with respect to the benefits and burdens of ownership analysis should come
from a series of post-Frank Lyon Tax Court decisions, and that the jury should
have been instructed to evaluate the factors in those cases as the exclusive
determinative indicia of ownership. The District Court disagreed, holding that
[t]o say * * * that the Tax Court's decisions identify the exclusive
criteria for determining which taxpayer is entitled to a depreciation
deduction would be to ignore the essential holding of Frank Lyon,
that whether a taxpayer possesses a depreciable interest in a leased
asset must be determined through a fact-intensive analysis focused on
the "substance and economic realities" of the challenged transaction.
* * * [Id. at 275.]
- 116 Altria further argued that even if the all-encompassing approach of Frank
Lyon is proper, several of the specific factors the court presented to the jury were
inappropriate. The District Court focused its discussion on two particular factors.
First, Altria argued that the court erred in instructing the jury to determine the
"likelihood" that the lessee counterparties would exercise their purchase options,
rather than instructing the jury to determine whether the purchase options were
"certain" or "nearly certain" to be exercised. The District Court held that Altria's
argument was merely one of semantics, since the "likelihood" of exercise includes
the possibility of a determination that it was "certain" or "nearly certain". It stated
that no Court of Appeals supports Altria's proposed standard and none has
addressed exactly "how likely" the exercise of an option must be to support a
conclusion that the taxpayer did not acquire a depreciable interest. Finally, and
most importantly, the District Court held that Altria's proposed instruction
misunderstood the Government's argument, i.e., that it was the cumulative effect
of each of the transactions' possible scenarios, and not just the purchase options,
that determines whether the benefits and burdens have passed.
Second, Altria argued that the District Court should have instructed the jury
to disregard present value in its residual interest analysis. The District Court
disagreed, finding that the present value analysis "properly sought to illuminate
- 117 the transactions' 'substance and economic realities', * * * particularly the relative
importance of the residual values nominally Altria stood to receive". Altria, 694
F. Supp. 2d at 280 (quoting Frank Lyon, 435 U.S. at 582).
Altria also argued against the use of a present value analysis as part of the
second prong of the economic substance test, whether Altria acted with a bona fide
business purpose. Citing rule 401 of the Federal Rules of Evidence, which
provides that "relevant evideríce" is "evidence having any tendency to make the
existence of any fact that is of consequence to the determination of the action more
probable or less probable", the District Court held that the Government's present
value analysis easily satisfied this test, and a reasonable factf'mder might conclude
that it is "less probable" that an investor had a reasonable business purpose for a
transaction with a negative net present value. Id. at 284-285. Altria also argued
that the use of a present value analysis in the business purpose test was
inconsistent with one of the District Court's other jury instructions, which was to
ignore present value in determining whether the transactions had "economic
effect", the first prong of the economic substance test. The District Court
dismissed this argument, holding that it was dependent on a "false dichotomy" and
that realizing transactional profit on a cash-in-cash-out basis is not the only
legitimate objective a business may pursue.
-118On appeal, the Court of Appeals for the Second Circuit addressed three
arguments with respect to substance over form. Altria, 658 F.3d at 286. First,
Altria challenged the District Court's decision that it was appropriate for the jury
to evaluate the "likelihood" that the lessee counterparties would exercise their
purchase options, again arguing that the jury should have been instructed to
evaluate whether exercise was "certain" or "nearly certain". The Court of Appeals
affirmed the District Court's position, holding that the purchase option is just one
factor in determining ownership and that the likelihood of the purchase options'
being exercised is not determinative of the analysis. Further, the court held that
neither the Supreme Court nor the Court of Appeals for the Second Circuit has
ever concluded that the true substance of a transaction is limited to events that are
"certain" or "virtually certain" to occur.
Altria argued that the jury instructions failed to provide any guidance on
what levels of equity investment or residual value are "meaningful" in the leasing
context, leaving the jury without a proper standard to work with. Altria requested
an instruction stating that a 6% equity investment and an expected residual value
of 10% to 20% would satisfy this threshold. The court dismissed this argument,
holding that a precise numerical test would encourage taxpayers to change the
form and not the substance of their transactions. Citing Frank Lyon, the court said
- 119 that the existence of a depreciable interest in an asset depends on the particular
facts of the case.
Finally, Altria argued that two of the factors included in the jury
instructions' nonexclusive list were "neutral" and therefore not relevant to
determining traditional lessor status. The first factor was control over the asset,
which Altria noted is present in all leveraged leases. The court rejected this
argument, holding that Frank Lyon specifically requires such an analysis. The
second factor was cashflows, which the court likewise rejected, citing the
relevance of circular cashflows to the courts in Wells Fargo, BB&T, and AWG.
Accordingly, the court affirmed the jury's findings that Altria did not obtain the
benefits and burdens of ownership with respect to its transactions.
E
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