American International Group, v. United States of America

  1. September 10, 2015

    Economic Substance Doctrine Bulks Up With 2nd Circ. Ruling

    The Second Circuit, in a Wednesday decision denying Bank of New York Mellon Corp. about $200 million in foreign tax credits, expanded the economic substance doctrine into what experts say may be too powerful of a tax collection weapon.

  2. September 09, 2015

    BNY Mellon's STARS Interest Deductible, 2nd Circ. Says

    The Second Circuit on Wednesday affirmed the U.S. Tax Court's decision denying Bank Of New York Mellon Corp.'s bid for foreign tax credits on a STARS transaction but allowing the bank to deduct interest paid on the underlying $1.5 billion loan.

  3. May 18, 2015

    AIG, BNY Fight For Foreign Tax Credits In 2nd Circ.

    American International Group Inc. and Bank of New York Mellon Corp. told the Second Circuit on Monday they had been wrongly denied foreign tax credits on billion-dollar loan transactions, disputing claims by the U.S. government that the deals lacked economic substance.

  4. October 17, 2014

    AIG Blasts IRS Economic Substance Claims In $306M Tax Row

    American International Group Inc. on Tuesday bashed the IRS for alleging that several transactions AIG used for foreign tax credits lacked economic substance, telling the Second Circuit the doctrine doesn't apply to the $306 million refund fight because the company complied with congressional standards.  

  5. October 01, 2014

    2nd Circ. Asked To Deny AIG $306M Tax Refund Appeal

    American International Group Inc. is not entitled to a refund of $306 million resulting from foreign tax credits disallowed by the Internal Revenue Service because the underlying transactions lacked economic substance, the federal government told the Second Circuit in a brief filed Monday.