In Salem Fin., Inc. v. United States, Fed. Cir., No. 14-05027, the U.S. Court of Appeals for the Federal Circuit upheld the Court of Federal Claims in determining that the trust component of the STARS transaction lacked economic substance thereby prohibiting the claim for foreign tax credits.  However, the court reversed the trial court and held that the loan portion of the transaction had economic substance, thus allowing for interest deductions for the interest paid on the loan.  The court also upheld the imposition of accuracy-related penalties, but remanded for a redetermination of the amount of penalties.