Salem Financial, Inc. Ex Rel. Branch Investments LLC v. United States

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• stating that the purpose of the “economic substance” component is “to assess a transaction’s economic reality, and in particular its profit potential, independent of the expected tax benefits”
• affirming trial court’s conclusion that STARS transaction “lacked economic reality” in part because the transaction “consisted of ‘three principal circular cash flows,’ which, apart from their intended tax consequences, had no real economic effect.”
• affirming trial courtʹs conclusion that STARS transaction ʺlacked economic realityʺ in part because the transaction ʺconsisted of ʹthree principal circular cash flows,ʹ which, apart from their intended tax consequences, had no real economic effect.ʺ
• “For purposes of this appeal, BB&T ‘accepts the trial court’s holding that the Trust Transaction and the Loan may be bifurcated.’ ” (citation omitted)
• for purposes -of appeal,, taxpayer did not contest lower court’s holding that transaction should be bifurcated
• “[C]laim- ing nearly $500 million in foreign tax credits by subjecting income to economically meaningless activities was ‘too good to be true.’”

Source: CourtListener parenthetical corpus (CC0).