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STARS tax shelter

District court upholds interest deductions and foreign tax credits from STARS transaction

District court upholds interest deductions and foreign tax credits from STARS transaction

Santander Holdings USA Inc. & Subsidiaries v. U.S., (DC MA 11/13/2015) 116 AFTR 2d ¶2015-5425 A district court has determined on summary judgment that a Structured Trust Advantaged Repackaged Securities (STARS) transaction had economic substance and that a participating bank was entitled to claim interest deductions and foreign tax credits stemming from participation in it. […]

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Second Circuit: banking corporation can deduct interest paid on STARS-related loan

Second Circuit: banking corporation can deduct interest paid on STARS-related loan

The Bank of New York Mellon Corporation v. Comm., (CA 2 9/9/2015) 116 AFTR 2d ¶ 2015-5219 The Court of Appeals for the Second Circuit, affirming the Tax Court, has held that a $1.5 billion loan that a banking corporation took out in association with a structured trust advantaged repackaged securities (STARS) transaction had independent […]

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U.S. court rejects AIG, Bank of NY Mellon tax credit appeals

U.S. court rejects AIG, Bank of NY Mellon tax credit appeals

NEW YORK (Reuters) – A U.S. appeals court on Wednesday rejected efforts by American International Group Inc and Bank of New York Mellon Corp to recoup hundreds of millions of dollars of foreign tax credits that the Internal Revenue Service did not allow. By a 3-0 vote, the 2nd U.S. Circuit Court of Appeals in New York […]

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DC Circuit applies Supreme Court’s holding on partnership item & outside basis

DC Circuit applies Supreme Court’s holding on partnership item & outside basis

Tigers Eye Trading, LLC, et al. v. Comm (CA DC 6/26/2015) 115 AFTR 2d ¶ 2015-862 Based on the Supreme Court’s recent holding in Woods, the Court of Appeals for the District of Columbia Circuit (DC Circuit) has affirmed the Tax Court’s decision that the Code Sec. 6662(h) gross valuation misstatement penalty applied to a partner in […]

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Court of Appeals denies STARS transaction foreign tax credits, allows interest deductions

Court of Appeals denies STARS transaction foreign tax credits, allows interest deductions

Salem Financial Inc., (CA FC 5/14/2015) 115 AFTR 2d ¶ 2015-743 The Court of Appeals for the Federal Circuit has ruled that the portion of a”structured trust advantaged repackaged securities” (STARS) transaction involving the use of a trust to generate foreign tax credits (FTCs) had no economic substance, but that the portion in which the […]

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Payment in STARS transaction demonstrated reasonable prospect of profit

Payment in STARS transaction demonstrated reasonable prospect of profit

In Santander Holdings USA, Inc., v. United States (DC MA 10/17/2013) 112 AFTR 2d ¶ 2013-5403, a district court has concluded that payments which a taxpayer received in a Structured Trust Advantaged Repackaged Securities (STARS) transaction were to be taken into account as pre-tax income to the taxpayer, rather than as a tax rebate, in […]

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Spanish bank gets partial win in STARS tax shelter fight

Spanish bank gets partial win in STARS tax shelter fight

As reported in Reuters – Banco Santander won a partial victory in a $234 million tax refund fight with the U.S. Internal Revenue Service over controversial tax shelters known as STARS when a Massachusetts district court ruled in favor of the Spanish bank. In several cases against banks with hundreds of millions of dollars at […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney