WASHINGTON – The Eighth Circuit Court of Appeals issued a precedential opinion on Friday, April 24, 2020, affirming a district court decision that a transaction designed to generate massive foreign tax credits (referred to as the STARS tax shelter) lacked economic substance and business purpose and was subject to the accuracy-related penalty for negligence, announced Principal Deputy Assistant Attorney General Richard E. Zuckerman and Deputy Assistant Attorney General Joshua Wu of the Justice Department’s Tax Division.In Wells Fargo v. United States, No. 17-3578, the Eighth Circuit Court of Appeals affirmed the decision of the U.S. District Court for the District of...