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This content has been archived.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 through our partners, LexisNexis® and Bloomberg Law.

To view this content, please continue to their sites.

Not a Lexis Advance® Subscriber?
Subscribe Now

Not a Bloomberg Law Subscriber?
Subscribe Now

Why am I seeing this?

LexisNexis® and Bloomberg Law are third party online distributors of the broad collection of current and archived versions of ALM's legal news publications. LexisNexis® and Bloomberg Law customers are able to access and use ALM's content, including content from the National Law Journal, The American Lawyer, Legaltech News, The New York Law Journal, and Corporate Counsel, as well as other sources of legal information.

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 © 2021 ALM Media Properties, LLC. All Rights Reserved.