Excerpt:
Wells Fargo couldn’t escape a 20 percent penalty for a $1.25 billion securities transaction, part of which has been deemed a tax-avoidance sham, but it won a partial victory to deduct interest paid on a foreign loan, under a Minnesota federal court’s ruling Wednesday. The case revolves around a highly complex structure called structured trust advantaged repackaged securities, or STARS, which a jury found in November consisted of two separate and independent transactions — a trust structure with no real economic or business purpose outside of... [...]