Monday, November 16, 2015

Judge Rules Thant IRS Owes $234M To Sovereign Bancorp

IRS Owes $234M To Sovereign In Tax Row, Judge Rules

A Massachusetts federal judge on Friday ruled that Sovereign Bancorp can recover some $234 million that it paid in taxes, interest and penalties to the federal government over an international securities transaction, finding the deal had a business purpose outside its tax benefits.

Granting a motion for summary judgment by Sovereign — now Santander Holdings USA Inc. — and denying a cross motion for partial summary judgment by the federal government, U.S. District Judge George A. O’Toole Jr. decided that the so-called structured trust advantaged repackaged securities, or STARS, transaction had economic substance.

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1 comment:

  1. The U.S. government said that it will appeal a $234 million tax award issued to Santander Group’s U.S. unit in a dispute in an international securities transaction, less than a week after the U.S. Supreme Court declined to hear a challenge to government determinations in similar cases.