BNY Mellon (BK) is facing a $900 million tax bill after a U.S. judge rejected its attempt to claim hundreds of millions of dollars in foreign tax credits.

The ruling on Monday by Judge Diane Kroupa of the U.S. Tax Court followed a determination by the Internal Revenue Service that BNY Mellon underpaid federal income taxes in 2000 and 2001. A transaction designed to generate roughly $199 million in foreign tax credits caused the shortfall.

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