United States First Circuit

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Santander Holdings USA, Inc. v. US, 16-1282

In a suit to obtain a refund from the IRS, concerning whether plaintiff, a U.S. taxpayer, is entitled to a refund from the IRS after the IRS began disallowing its claim for foreign tax credits and imposing accuracy-related penalties in 2008, the district court's judgment is reversed as to the economic substance of the Trust transaction at issue and the foreign tax credits claimed for the Trust transaction, where the Trust transaction was not a legitimate business and lacked economic substance.

Appellate Information

  • Argued
  • Submitted
  • Decided
  • Published 2016/12/16




  • United States First Circuit


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