The US Tax Court has disallowed foreign tax credits (FTCs), expense deductions, and foreign-source income treatment from a structured financial transaction based on the economic substance doctrine. (Bank of New York Mellon Corporation, as Successor in Interest to The Bank of New York Company, Inc. v. Commissioner of Internal Revenue, 140 T.C. No. 2, Docket No. 26683-09 (11 February 2013)).

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