Wells Fargo & Company v. United States
Case Number:
17-3578
Court:
Nature of Suit:
Companies
Sectors & Industries:
-
July 02, 2020
Top Federal Tax Decisions Of 2020: Midyear Report
In the first six months of 2020, the U.S. Supreme Court addressed two long-standing precedents involving tax laws and struck one down in the process, while the U.S. Tax Court decided several cases involving the use of conservation easement deductions. Here, Law360 examines a few of the most important tax decisions in federal courts from the year's first half.
-
April 24, 2020
8th Circ. Won't Revive Wells Fargo Foreign Tax Credit Case
The Eighth Circuit declined Friday to revive Wells Fargo's bid to reclaim foreign tax credits tied to a transaction with U.K.-based Barclays worth more than $1.25 billion, finding the arrangement was a sham with no economic substance.
-
July 08, 2019
Kisor Ruling Shouldn't Limit Treasury Deference, 8th Circ. Told
The U.S. Treasury is entitled to deference in its interpretation of regulations in its $300 million tax dispute with Wells Fargo, despite the U.S. Supreme Court decision in Kisor v. Wilkie limiting deference, the U.S. has told the Eighth Circuit.
-
July 30, 2018
Wells Fargo Defends Intent In $300M Tax Row In 8th Circ.
In an Eighth Circuit fight over more than $300 million in foreign tax credits, Wells Fargo hit back Monday at the government's assertion that transactions lacking economic substance should have no tax benefits, saying the real question is whether it reasonably believed its transactions had economic substance.
-
July 12, 2018
Wells Fargo Says Gov't Double-Taxed By Denying $300M Credit
A transaction where Barclays would offset part of Wells Fargo's British tax liability by making payments through a trust was done to make a profit and not for tax purposes, entitling Wells Fargo to a $300 million tax credit erroneously denied by a federal district court, it argued to the Eighth Circuit Wednesday.
-
June 06, 2018
Feds Say Wells Fargo's Tax Credit Claim Based On A Sham
The U.S. government urged the Eighth Circuit on Wednesday to reject Wells Fargo's bid for more than $300 million in foreign tax credits, saying that a Minnesota federal court had already correctly found that the credits were artificially generated through a tax-avoidance sham.
-
April 19, 2018
Wells Fargo Asks 8th Circ. To Salvage Foreign Tax Credits
Wells Fargo appealed the loss of foreign tax credits in a lawsuit over a securities transaction worth more than $1.25 billion, telling the Eighth Circuit Wednesday that a Minnesota federal court had wrongly allowed a jury to decide its transaction was a sham.