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Wells Fargo Can't Deduct Tax In Sham Barclays Transaction

Law360, New York (September 18, 2017, 4:59 PM EDT) -- A last-minute bid by Wells Fargo & Co. to deduct $150 million in foreign taxes was blocked by a Minnesota federal judge Friday, who found the complex transaction that generated the tax was a sham and the bank’s request for relief came too late.

The order by U.S. District Judge Patrick Schiltz addressed the final unsettled issue that remains in the bank’s seven-year feud with the IRS over a $1.25 billion structured trust advantaged repackaged securities transaction it constructed with Barclays PLC; the bank’s attempt to...
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Case Information

Case Title

Wells Fargo & Company v. United States of America


Case Number

0:09-cv-02764

Court

Minnesota

Nature of Suit

Taxes

Judge

Patrick J. Schiltz

Date Filed

October 5, 2009

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