Lehman Brothers Financial SA (LEHNQ)

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The claim against the US Internal Revenue Service (IRS) was for a significant tax refund, including interest, that LBIE was pursuing as part of its administration process.

The final outcome and amount of the claim were a key factor influencing the final returns for LBH's subordinated creditors.

AI
The claim against the US Internal Revenue Service (IRS) mentioned in the excerpt is for interest on a previously settled tax matter [1].
Specific details regarding the nature and current status of this particular claim are limited, but it is a claim for interest on a tax refund [1]. It was excluded from the sale of remaining assets from LBIE to LBH because it was considered a potential recovery stream that the administrators likely intended to pursue separately for the benefit of creditors [1].
The administrators' reports describe it as the "remaining claim for interest from the US Internal Revenue Service" [1]. The pursuit and potential recovery from this claim represent some of the final outstanding tasks in the very long-running administration of the Lehman Brothers UK entities [1].
The claim against the US Internal Revenue Service (IRS) was for a significant tax refund, including interest, that LBIE was pursuing as part of its administration process.
Key details about the claim:
Competent Authority Approval: The IRS approved LBIE's request for treaty benefits through the competent authority process in August 2021, which allowed for the recovery of taxes.
Progress: Tax returns were filed in the fourth quarter of 2021, and the administrators of LBIE were in continuous liaison with the IRS regarding the payment of the refund.
Timing Uncertainty: The final approval and timing of the refund payment were uncertain and outside the administrators' influence, as it was awaiting final review by the IRS' Joint Committee of Taxation.
Exclusion from Asset Sale: In the October 2025 transaction, LBIE sold most of its remaining assets to LBH, but it specifically retained this claim for interest from the IRS. This means the proceeds from this specific claim, once realized, would go directly to the LBIE estate rather than being bundled into the c.£16.5m consideration paid by LBH for the other assets.
The status as of progress reports from September 2024 indicated that LBIE continued to wait for the refund. The final outcome and amount of the claim were a key factor influencing the final returns for LBH's subordinated creditors.