In terms of the types of loopholes that are addressed, there is certain planning with respect to leveraged life insurance and leveraged insured annuities. More particularly, there are also changes with respect to the taxation of trust attributes and corporate loss trading transactions. Those are types of transactions that seek to use corporate losses and business losses incurred by trusts as essentially a commodity that can be traded between entities.
The measures would mean losses could be used only under appropriate circumstances, thereby allowing the tax system to prevent a particular taxpayer who has incurred a loss from using it for anything other than to recoup it in the operation of their business, instead of being able to transfer it to other taxpayers.