The Treasury and IRS announced Friday in Notice 2005-13 that sale-in, lease-out ("SILO") transactions are designated as listed tax shelter transactions. As a result, taxpayers will have to disclose their involvement in SILOs to the IRS. The American Jobs Creation Act limits the deductibility of losses from future SILO agreements. Notice 2005-15 thus affects investors in SILOs prior to March 12, 2004. The contact person on Notice 2005-13 is John Aramburu (CC:ITA:B05) ((202) 622-4960).
- Notice 2005-13, 2005-9 I.R.B. 1
- Treasury Department Press Release (JS-2249)
