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Santander Fights 1st Circ. ‘Tax Shelter’ Designation, Fines

Law360, Boston (March 12, 2018, 10:17 PM EDT) -- Santander Group continued on Monday to deny having operated a tax shelter in the United Kingdom over a year after the First Circuit ruled the questionable trust's “whole function” was generating foreign tax credits.

Counsel to the bank disputed the appellate court’s judgment in a bid to escape penalties at a marathon hearing in Boston. Raj Madan argued tax regulations were on the bank’s side from 2003 to 2005, when the group then known as Sovereign Bancorp. capitalized on nations’ differing tax codes to a tune of $234 million, which...
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