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Tuesday, February 12, 2013

Tax Court Denies BNY Mellon $199 Million of Foreign Tax Credits in STARS Tax Shelter

Tax Court Logo 2The 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).

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