Today, the US Supreme Court denied certiorari in foreign tax generator cases Salem Fin., Inc. v. United States, 786 F.3d 932, 2015 BL 148218 (Fed. Cir. 2015), cert. denied (U.S. 3/7/16) (No. 15-380), and Bank of N.Y. Mellon Corp. v. Commissioner and American International Group Inc. v. Commissioner, 801 F.3d 104, 2015 BL 290907 (2d Cir. 2015),cert. denied (U.S. 3/7/16) (AIG No. 15-478) (BNY No. 15-572) (the AIG and BNY cases were originally consolidated but the taxpayers filed separate cert petitions).  These cases involved structured trust advantaged repackaged securities (STARS) transactions for which the taxpayers claimed foreign tax credits.  In both cases, the lower courts held that the STARS transactions lacked an economic substance because they did not offer the opportunity for profit other than from the anticipated tax benefit.