BNY Mellon Barred From $199 Million of Foreign Tax Credit

Bank of New York Mellon Corp. was prohibited by the U.S. Tax Court from claiming $199 million of foreign tax credits generated in a transaction arranged by Barclays Bank Plc and KPMG LLP.

The tax court said BNY Mellon couldn’t claim the tax credits and related expense deductions for 2001 and 2002 because the underlying transaction with London-based Barclays “lacked economic substance.”