For over 50 years, Bloomberg Tax’s renowned flagship daily news service, Daily Tax Report® has helped leading practitioners and policymakers stay on the cutting edge of taxation and...
Jan. 7 — A Federal Circuit panel hearing the first appeals-level STARS case seemed receptive to, at a minimum, allowing BB&T the interest deduction on the loan component of the transaction (Salem Fin., Inc. v. United States, Fed. Cir., No. 14-05027, oral arguments 1/7/15).
The government's counsel, Judith A. Hagley, said during oral arguments Jan. 7 before the U.S. Court of Appeals for the Federal Circuit that BB&T Corp. wasn't entitled to the deduction, because the loan wasn't for a non-tax purpose, but the judges appeared more accepting of BB&T's argument that the loan proceeds were used in BB&T's banking business.
The panel, consisting of Judges William C. Bryson, Kathleen M. O'Malley and Todd M. Hughes, didn't appear particularly hostile or friendly to either side regarding the treatment of payments made to BB&T by Barclays Bank PLC. The payments were related to U.K. tax credits received by Barclays in the trust component of the structured trust advantaged repackaged securities (STARS) transaction.
All Bloomberg BNA treatises are available on standing order, which ensures you will always receive the most current edition of the book or supplement of the title you have ordered from Bloomberg BNA’s book division. As soon as a new supplement or edition is published (usually annually) for a title you’ve previously purchased and requested to be placed on standing order, we’ll ship it to you to review for 30 days without any obligation. During this period, you can either (a) honor the invoice and receive a 5% discount (in addition to any other discounts you may qualify for) off the then-current price of the update, plus shipping and handling or (b) return the book(s), in which case, your invoice will be cancelled upon receipt of the book(s). Call us for a prepaid UPS label for your return. It’s as simple and easy as that. Most importantly, standing orders mean you will never have to worry about the timeliness of the information you’re relying on. And, you may discontinue standing orders at any time by contacting us at 1.800.960.1220 or by sending an email to firstname.lastname@example.org.
Put me on standing order at a 5% discount off list price of all future updates, in addition to any other discounts I may quality for. (Returnable within 30 days.)
Notify me when updates are available (No standing order will be created).
This Bloomberg BNA report is available on standing order, which ensures you will all receive the latest edition. This report is updated annually and we will send you the latest edition once it has been published. By signing up for standing order you will never have to worry about the timeliness of the information you need. And, you may discontinue standing orders at any time by contacting us at 1.800.372.1033, option 5, or by sending us an email to email@example.com.
Put me on standing order
Notify me when new releases are available (no standing order will be created)