US
Court of Appeals affirms NatWest case – US branch interest rules violate 1975 US-UK income tax treaty
The US Court of Appeals for the Federal Circuit has affirmed lower court decisions holding that the US branch interest allocation rules of Treasury Regulation § 1.882-5 violate Art. 7 (Business profits) of the 1975 US-UK Income Tax Treaty in National Westminster Bank PLC v. United …
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