« Tax Policy Center Hosts Program Tomorrow on Time to Rethink Retirement Saving Policy? | Main | Johnston: Bermuda Robs Sacramento and Albany -- Who Knew? »
February 12, 2013
Tax Court Denies BNY Mellon $199 Million of Foreign Tax Credits in STARS Tax Shelter
The Tax Court yesterday held that a structured trust advantaged repackaged securities (STARS) transaction lacked economic substance and denied $199 million of foreign tax credits claimed by BNY Mellon. Bank of New York Mellon Corp. v. Commissioner, 140 T.C. No. 2 (Feb. 11, 2013).
- Bloomberg, BNY Mellon Barred From $199 Million of Foreign Tax Credit
- Chicago Tribune, BNY Mellon Loses U.S. Tax Case, to Take $850 Million Profit Hit
- Financial Times, US Court Bars BNYMellon Tax Credits
- Wall Street Journal, IRS Wins Major Tax Shelter Case
February 12, 2013 in Tax | Permalink
TrackBack
TrackBack URL for this entry:
http://www.typepad.com/services/trackback/6a00d8341c4eab53ef017c36cbaefa970b
Listed below are links to weblogs that reference Tax Court Denies BNY Mellon $199 Million of Foreign Tax Credits in STARS Tax Shelter:
