Legal Opinion
Santander Holdings USA, Inc. v. United States
District Court, D. Massachusetts
Decided November 13, 2015No. CIVIL ACTION NO. 09-11043-GAOPublishedCited by 2 opinions
1Opinion of the Court
OPINION AND ORDER
O’TOOLE, DISTRICT JUDGE.
Santander Holdings USA, Inc., formerly known as Sovereign Bancorp, Inc., and referred to in this opinion as “Sovereign,” has sued to recover approximately $234 million in federal income taxes, penalties, and interest that it claims were improperly assessed and collected by the Internal Revenue Service for tax years 2003, 2004, and 2005 as a result of the IRS’s disallowance of foreign tax credits claimed by Sovereign for those years. The tax credits were claimed as a consequence of Sovereign’s participation in a “Structured Trust Advantaged Repackaged…
2Cases cited9 opinions
- Old Colony Trust Co. v. CommissionerSupreme Court of the United States · 1929
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Compaq Computer Corporation & Subsidiaries v. CommissionerCourt of Appeals for the Fifth Circuit · 2001
- Alliant Energy Corp v. United StatesCourt of Appeals for the Eighth Circuit · 2001
- Bank of New York Mellon Corp. v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 2015
4 more not listed; retrieve them via the Exa API.
3Cited by2 opinions
- Santander Holdings USA, Inc. v. United StatesCourt of Appeals for the First Circuit · 2016
- Sovereign Bancorp, Inc. v. United StatesDistrict Court, D. Massachusetts · 2018