BNY Mellon will appeal U.S. Tax Court ruling BNY Mellon issued the following statement in response to a ruling published by the U.S. Tax Court regarding the IRS's disallowance of certain foreign tax credits claimed for the 2001 and 2002 tax years: "We will appeal the court's decision. We continue to believe the tax treatment of the transaction was consistent with statutory and judicial authority existing at the time. As a result of the ruling, BNY Mellon expects to take an after-tax charge of approximately $850M during the first quarter of 2013. After taking the charge, the company expects it will continue to be well capitalized and its Basel III Tier 1 common equity ratio will be impacted by approximately 55 basis points. At December 31, 2012, our Basel III Tier 1 common equity ratio was 9.8%."