Santander Holdings USA, Inc. v. US

  1. March 22, 2017

    Justices Urged To Resolve Split Over Key To $234M Tax Row

    Santander Holdings USA Inc. asked the U.S. Supreme Court to hear its effort to win back a $234 million foreign tax credit refund the First Circuit had overturned, arguing that different courts had conflicting rulings on a key component of the case.

  2. December 16, 2016

    1st Circ. Reverses Santander's $234M Foreign Tax Refund Win

    The First Circuit overturned an earlier $234 million victory for Santander Holdings USA Inc. after ruling on Friday that an internal securities transaction the bank had engaged in lacked economic substance and does not qualify for foreign tax credits.

  3. November 09, 2016

    Feds Urge 1st Circ. To Nix Santander's $234M Tax Win

    The federal government on Wednesday asked the First Circuit to reverse a ruling that it owes Santander Holdings USA $234 million in tax refunds, penalties and interest, saying that the internal securities transactions at issue didn't have any economic substance.

  4. September 15, 2016

    Feds Blast Santander Group's Bid To Preserve $234M Tax Win

    The federal government swatted down arguments from Santander Group to preserve a $234 million tax award to its U.S. unit at the First Circuit, arguing Thursday that the lower court should have paid more attention to whether the transaction had economic substance than its context.

  5. August 23, 2016

    Biz Groups Dispute Gov't Claim In $234M Foreign Tax Suit

    Business groups and a public interest law firm urged the First Circuit on Monday to reject the federal government’s interpretation of an economic substance doctrine in a $234 million foreign tax credits dispute, saying that the government’s meaning could lead to double taxation.

  6. August 16, 2016

    Santander Says IRS Twisting UK Deal To Deny $234M Award

    The Santander Group pushed back on the U.S. government's First Circuit appeal of a $234 million tax award issued to the group's U.S. unit in a dispute over an international securities transaction, on Monday maintaining that the government has twisted the transaction to call it a "sham."