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ARTICLE · 15 NOVEMBER 2013

Focus on Tax Controversy and Litigation

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This month’s issue features articles about the agreement between the United States and Switzerland on an amnesty program for Swiss banks; the Sovereign Bancorp decision, in which a Massachusetts district court held that a STARS transaction had objective economic substance; and the Salem Financial decision, in which the Court of Federal Claims held that a STARS transaction failed the economic substance test.

United StatesFinance and Banking

This month's issue features articles about the agreement between the United States and Switzerland on an amnesty program for Swiss banks; the Sovereign Bancorp decision, in which a Massachusetts district court held that a STARS transaction had objective economic substance; and the Salem Financial decision, in which the Court of Federal Claims held that a STARS transaction failed the economic substance test.


View newsletter, "Focus on Tax Controversy and Litigation: District Court Rules for Taxpayer in STARS Case Santander Holdings; Court of Federal Claims Rules for Government in STARS Case Salem Financial

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