The following is a quote from the U.S. District Court, D. Massachusetts, regarding a “Structured Trust Advantaged Repackaged Securities” (“STARS”) transaction:
[T]he transaction was surpassingly complex and unintuitive; the sort of thing that would have emerged if Rube Goldberg had been a tax accountant.
Santander Holdings USA, Inc. v. U.S., 2013-2 U.S.T.C. ¶50,564, (Oct. 17, 2013)
