United States Second Circuit

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The Bank of New York Mellon Corp. v. Commissioner of Internal Revenue, 14-704

In an appeal and cross-appeal heard in tandem from a judgment of the US Tax Court, the district court's judgment is affirmed where it properly concluded that the "economic substance doctrine" applies to transactions involving foreign tax credits generally and that foreign taxes are to be included in calculating pre-tax profit.

Appellate Information

  • Decided 09/10/2015
  • Published 09/10/2015


  • CHIN


  • United States Second Circuit


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