Legal Opinion
Bank of New York Mellon Corp. v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
Decided September 9, 2015No. Nos. 14-704-ag(L), 14-1394-ag(XAP), 14-765-cvPublishedCited by 16 opinions
1Opinion of the Court
CHIN, Circuit Judge:
These appeals and cross-appeal, heard in tandem, challenge an opinion and order of the United States District Court for the Southern District of New York (Stanton, J.) and a judgment of the United States Tax Court (Kroupa, J.) applying the “eco*107nomic substance doctrine” to transactions involving foreign tax credits. In both cases, the taxpayers claim they are entitled to tax credits associated with foreign transactions that the government disallowed because it contends the transactions lacked economic substance.
In American International Group., Inc. v. United States, in…
2Cases cited34 opinions
- Gregory v. HelveringSupreme Court of the United States · 1935
- Commissioner v. Court Holding Co.Supreme Court of the United States · 1945
- Frank Lyon Co. v. United StatesSupreme Court of the United States · 1978
- Rice's Toyota World, Inc. (Formerly Rice Auto Sales, Inc.) v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1985
- The Black & Decker Corporation v. United StatesCourt of Appeals for the Fourth Circuit · 2006
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3Cited by16 opinions
- Auto Ind. Pension Trust Fund v. Toshiba Corp.Court of Appeals for the Ninth Circuit · 2018
- United States v. DaugerdasCourt of Appeals for the Second Circuit · 2016
- Santander Holdings USA, Inc. v. United StatesCourt of Appeals for the First Circuit · 2016
- Wells Fargo & Company v. United StatesCourt of Appeals for the Eighth Circuit · 2020
- Benenson v. Comm'rCourt of Appeals for the Second Circuit · 2018
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