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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 States, Docket No. 2007-5028 (15 January 2008).
The US Court of Federal Claims ha…
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