Jon Irenicus and Phylactery Lich on the battlefield.
An opponent does not control a permanent with a phylactery counter on it.
Steps
At the beginning of your end step, Jon Irenicus triggers, giving control of Phylactery Lich to an opponent who controls no permanents with a phylactery counter on them.
When Phylactery Lich's controller controls no permanents with a phylactery counter on them, Phylactery Lich triggers, causing them to sacrifice it.
However, Phylactery Lich cannot be sacrificed due to its ability.
Phylactery Lich triggers again, creating a mandatory infinite loop that causes the game to end in a draw.