Wells Fargo decision sheds light on economic substance doctrine

February 10 2010

The decision that the Court of Federal Claims reached in the case of Wells Fargo & Company and Subsidiaries v. United States on January 8 is still reverberating in the US tax community.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

‘Huge, complex’ pillar two system encroaches on sovereignty: EY tax leader

Tax expert Craig Hillier agrees with the comparison of pillar two to using a sledgehammer to crack a nut

Sam Sholli, July 14 2025

Direct Tax

London- HM Revenue and Customs building on Whitehall, UK Governm

HMRC believes US companies underpaid £8.8bn in tax: accountancy group

The amount is reported to be up 57% from the £5.6bn that the UK tax agency believes was underpaid in the previous year

Sam Sholli, July 14 2025

Indirect Tax

This week in tax: Donald Trump announces 50% tariff on Brazil

The US president also unveiled a new 50% levy on copper imports; in other news, a UK wealth tax proposal has been criticised by the Institute for Fiscal Studies

Sam Sholli, July 11 2025

Direct Tax

Exclusive: WTS Global CEO steps down

Wim Wuyts, who had been head of the specialist tax network since 2017, is moving on to a new role with WTS’s Belgian member firm

Tom Baker, July 10 2025

Transfer Pricing

When algorithms decide tax outcomes: embedding ethics in TP systems

MNEs are increasingly using algorithmic tools in TP. Sahasranshu Dash argues that data ethics should therefore plug directly into the TP design process

Sahasranshu Dash , July 10 2025

Transfer Pricing