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

Civil Action No. 09-11043-GAO.

977 F.Supp.2d 46 (2013)

SANTANDER HOLDINGS USA, INC. & SUBSIDIARIES, Plaintiff, v. UNITED STATES of America, Defendant.

United States District Court, D. Massachusetts.

October 17, 2013.

Attorney(s) appearing for the Case

Christopher Bowers , Rajiv Madan , John Magee , Christopher P. Murphy , Royce Tidwell , Nathan P. Wacker , Nicholas L. Wilkins , Bingham McCutchen LLP, Washington, DC, Deana K. El-Mallawany , James C. McGratn , Bingham McCutchen LLP-MA, Boston, MA, for Plaintiff.

Raagnee Beri , William E. Farrior , Alan S. Kline , Kari M. Larson , John L. Schoenecker , U.S. Department of Justice, Dennis M. Donohue Washington, DC, for Defendant.

OPINION

O'TOOLE, District Judge.

Santander Holdings USA, Inc., formerly known as Sovereign Bancorp, Inc., and referred to in this opinion as "Sovereign," has sued to recover approximately $234 million in federal income taxes, penalties, and interest that it claims were improperly assessed and collected by the Internal Revenue Service for tax years 2003, 2004, and 2005 as a consequence of the IRS's disallowance of foreign tax credits claimed by Sovereign...

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