5-Year Eligibility Limitation Waiver for Tangible Property Regs Extended One Year (Notice 2017-6)

The IRS has extended for an additional year the waiver of the 5-year eligibility limitation on making automatic accounting method changes to comply with the tangible property regulations (“repair regulations”) generally provided in Reg. §1.263(a)-1, Reg. §1,263(a)-2, and Reg. §1.263(a)-3) (T.D. 9636 (September 19, 2013)) and certain related final MACRS regulations (T.D. 9689 (August 14, 2014)). As extended, the 5-year eligibility limitation will not apply to changes made for tax years beg... read more...

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 that foreign tax credits would be available for this type of generated transaction. Comment.<... read more...