Wells Fargo & Co. v. United States

ORDER

Patrick J. Schütz, United States District Judge

• This long-running tax litigation arises out of an extraordinarily complex transaction that plaintiff Wells Fargo & Company (“Wells Fargo”) engaged in with Barclays, a British financial-services company. The transaction — called “Structured Trust Advantaged Repackaged Securities” or “STARS” — included four key elements: (1) Wells Fargo would voluntarily subject some of its income-producing assets to U.K. taxation by placing them in a trust with a U.K. trustee; (2) Wells Fargo would offset those U.K. taxes by claiming foreign-tax credits on…