Robert W. Wood & Steven E. Hollingworth (both of Wood & Porter, San Francisco) have published DSILOs and LILOs Demystified, 129 Tax Notes 195 (Oct. 12, 2010):

SILOs and LILOs are large and complicated leveraged lease transactions, often involving domestic and foreign infrastructure, in which U.S. investors seek tax benefits from otherwise tax-exempt assets. In this report, Wood and Hollingworth demystify the mechanics of these complex structures and summarize the state of the administrative and case law, some of which has yet to be written.

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