Companies Rejected by U.S. Supreme Court in $1.5 Billion Tax Cases

  • BNY Mellon, AIG and BB&T turned away on tax-avoidance strategy
  • Lower courts said Barclays strategy lacked economic substance

The U.S. Supreme Court is seen in at dusk on Feb. 14, 2016 in Washington.

Photographer: Drew Angerer/Getty Images

The U.S. Supreme Court turned away appeals from three financial-services companies that sought to save a total of $1.5 billion by using a tax-avoidance strategy designed by Barclays Plc.

The nation’s highest court, without comment, rejected separate appeals by Bank of New York Mellon Corp., American International Group Inc. and a unit of BB&T Corp. All three companies were seeking to overturn federal appeals court rulings that said the Barclays strategy lacked economic substance.

The cases centered on foreign tax credits generated using an approach known as Structured Trust Advantaged Repackaged Securities, or STARS.

BB&T was trying to recoup $600 million from the IRS, while AIG was seeking a refund of more than $306 million. Mellon said the multifaceted court fight reduced its 2013 after-tax income by $593 million.

The Obama administration urged the Supreme Court not to take up the appeals.

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