Legal Opinion
Salem Financial, Inc. v. United States
United States Court of Federal Claims
Decided September 20, 2013No. 10-192TPublishedCited by 9 opinions
1Opinion of the Court
Tax Refund Suit; STARS Structured Transaction Between BB & T Bank and Bar-clays Bank; Availability of Foreign Tax Credits From Payment of United Kingdom Taxes; Deductions for Interest and Transaction Costs; Economic Substance Doctrine Applied to Trust and Loan Components of Transaction; Assessment of Penalties.
OPINION AND ORDER
WHEELER, Judge.
In this tax refund case, the Court must determine the proper tax treatment for an unusually complex financial transaction known as STARS (“Structured Trust Advantaged Repackaged Securities”). Plaintiff, Salem Financial, Inc. (“Salem”), is a subsidiary of…
2Cases cited54 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. TowerSupreme Court of the United States · 1946
- Moline Properties, Inc. v. CommissionerSupreme Court of the United States · 1943
- Knetsch v. United StatesSupreme Court of the United States · 1960
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
49 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Salem Financial, Inc. Ex Rel. Branch Investments LLC v. United StatesCourt of Appeals for the Federal Circuit · 2015
- Santander Holdings USA, Inc. & Subsidiaries v. United StatesDistrict Court, D. Massachusetts · 2013
- Albemarle Corporation & Subsidiaries v. United StatesUnited States Court of Federal Claims · 2014
- Salem Financial, Inc. v. United StatesUnited States Court of Federal Claims · 2017
- Salem Financial, Inc. v. United StatesUnited States Court of Federal Claims · 2014
4 more not listed; retrieve them via the Exa API.