Thank you for sharing!

Your article was successfully shared with the contacts you provided.
Tax litigators at ShawPittman and Davis Polk & Wardwell have scored an important ruling for the international banking community. The U.S. Court of Federal Claims ruled July 7 that under the terms of the U.S.-U.K. income treaty, the IRS could not require National Westminster Bank Plc, a major British-based international bank, to use the IRS’s regulatory formula to determine its U.S. tax deductible interest expense. The case, in which ShawPittman and Davis Polk & Wardwell are co-counsel for Natwest, involves a potential refund of over $237 million of taxes and interest paid by the bank. The IRS had assessed tax against Natwest under a complex regulatory formula, which the Court found to be “fundamentally incompatible” with the treaty. Its decision is expected to have implications for banks in countries who have entered similar tax treaties with the U.S.

This content has been archived. It is available exclusively through our partner LexisNexis®.

To view this content, please continue to Lexis Advance®.

Not a Lexis Advance® Subscriber? Subscribe Now

Why am I seeing this?

LexisNexis® is now the exclusive third party online distributor of the broad collection of current and archived versions of ALM's legal news publications. LexisNexis® customers will be able to access and use ALM's content by subscribing to the LexisNexis® services via Lexis Advance®. This includes content from the National Law Journal®, The American Lawyer®, Law Technology News®, The New York Law Journal® and Corporate Counsel®, as well as ALM's other newspapers, directories, legal treatises, published and unpublished court opinions, and other sources of legal information.

ALM's content plays a significant role in your work and research, and now through this alliance LexisNexis® will bring you access to an even more comprehensive collection of legal content.

For questions call 1-877-256-2472 or contact us at [email protected]


ALM Legal Publication Newsletters

Sign Up Today and Never Miss Another Story.

As part of your digital membership, you can sign up for an unlimited number of a wide range of complimentary newsletters. Visit your My Account page to make your selections. Get the timely legal news and critical analysis you cannot afford to miss. Tailored just for you. In your inbox. Every day.

Copyright © 2020 ALM Media Properties, LLC. All Rights Reserved.