United States:
Focus on Tax Controversy and Litigation
15 November 2013
Shearman & Sterling LLP
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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.
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
The content of this article is intended to provide a general
guide to the subject matter. Specialist advice should be sought
about your specific circumstances.
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