Tuesday, February 12, 2013
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