Wells Fargo & Co. v. United States

ORDER

Patrick J. Schütz, United States District Judge

In 2001, Barclays Bank, PLC — a British financial-services company — started marketing to American banks a product called “Structured Trust Advantaged Repackaged Securities” or “STARS.” Barclays proposed to American banks that they partner with Barclays in a series of complicated transactions designed to exploit differences between the tax laws of the United States and the tax laws of the United Kingdom. The plan had four key elements: (1) the American bank would voluntarily subject some of its income-producing assets to U.K. taxation; (2)…