Number: RL32479
Title: Tax Implications of SILOs, QTEs, and Other Leasing Transactions with Tex-Exempt Entities
Authors: Maxim Shvedov, Government and Finance Division 
Abstract: Provisions related to certain leasing transactions became an important part of the foreign sales corporation/extraterritorial income exclusion (FSC/ETI) Act signed into law by President Bush on October 22, 2004 (P.L. 108-357). The original House and Senate versions of these major corporate tax bills were different from the final version of the provision, but in both bills the provisions were major revenue raisers and as such have drawn considerable interest. This report explains the types of leasing transactions the law targets, briefly discusses the legislative and regulatory history related to leasing, and compares various versions of the bills in question.
Pages: 17
Date: November 30, 2004