STARS Transaction Lacked Economic Substance

Bank Not Entitled to Refund (Santander Holdings USA, Inc., CA-1)

A federal district court committed reversible error when it determined that a bank was entitled to tax benefits generated by a structured trust advantaged repackaged securities (STARS) transaction. The STARS transaction lacked economic substance because it had no objective nontax economic benefit and Congress did not intend...

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Guidance Issued Regarding User Fee Exemption for Employee Plans Determination Letter Applications (Notice 2017-1)

The IRS has provided guidance on the circumstances under which the IRS will treat an application for a determination letter as being filed within a qualifying open remedial amendment period. The guidance reflects changes made to the determination letter program and remedial amendment period rules in Rev. Proc. 2016-37, I.R.B. 2016-29, 136. The IRS will treat an application for a determination l...

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Washington Business and Occupation Tax

Economic Nexus Thresholds Announced

The Washington Department of Revenue has announced that for calendar year 2017, the economic nexus thresholds applicable to apportionable activities for business and occupation (B&O) tax purposes will remain as follows: receipts threshold, $267,000; property threshold, $53,000; and payroll threshold, $53,000. Excise Tax Advisory No. 319...

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