Shearman And Sterling

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Nov 06, 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.

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