Sheltering ICO Gain

Disclaimer 

[To Come]

For example, if the company described above took $35 mm in the first year and invested it in a a qualifying equipment lease, it might have results along the line of a net $5 mm tax loss in year 1, ~$6.5 mm loss in year 2, ~$4.5 mm in year 3, followed by $21 mm of income in year 4.  A transaction like this effectively shifts $21 mm of loss into years where a refund can be claimed ($8.4 mm worth), and the money has to be invested somewhere.  (Yes, of course, leases are higher risk than Treasury Notes, but maybe that risk is manageable.)

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