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SANTANDER HOLDINGS USA, INC. v. U.S.

No. 16-1282.

844 F.3d 15 (2016)

SANTANDER HOLDINGS USA, INC., and Subsidiaries, f/k/a Sovereign Bancorp., Inc., Plaintiff, Appellee, v. UNITED STATES of America, Defendant, Appellant.

United States Court of Appeals, First Circuit.

December 16, 2016.

Attorney(s) appearing for the Case

Judith A. Hagley , with whom Caroline D. Ciraolo , Acting Assistant Attorney General, Tax Division, Diana L. Erbsen , Deputy Assistant Attorney General, Tax Division, Gilbert S. Rothenberg , Richard Farber , Washington, DC, and Carmen M. Ortiz , United States Attorney, were on brief, for appellant.

Jonathan S. Massey , Washington, DC, with whom Leonard A. Gail , Chicago, IL, Paul J. Berks , Massey & Gail LLP, Rajiv Madan , and Skadden, Arps, Slate, Meagher & Flom LLP were on brief, for appellee.

Martin S. Kaufman , Scarsdale, NY, on brief for Atlantic Legal Foundation, amicus curiae.

Scott P. Martin , Gibson, Dunn & Crutcher LLP, Washington, DC, Kate Comerford Todd , Steven P. Lehotsky , Washington, DC, Warren Postman , and U.S. Chamber Litigation Center on brief for Chamber of Commerce of the United States of America, amicus curiae.

Derek T. Ho , Bradley E. Oppenheimer , William H. Milliken , Kellogg, Huber, Hansen, Todd, Evans & Figel, P.L.L.C., Washington, DC, and K. Richard Foster on brief for Financial Services Roundtable, amicus curiae.

Before Lynch and Selya, Circuit Judges, and Burroughs, District Judge.

Under the Internal Revenue Code, taxpayers receive, subject to various technical requirements, credits against owed U.S. income tax for every dollar paid to a foreign country for taxable international business transactions of economic substance. See 26 U.S.C. §§ 901-909. Over the past decade...

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