The Resource U.S. court rejects formula apportionment in computing business profits of a foreign bank branch

U.S. court rejects formula apportionment in computing business profits of a foreign bank branch

Label
U.S. court rejects formula apportionment in computing business profits of a foreign bank branch
Title
U.S. court rejects formula apportionment in computing business profits of a foreign bank branch
Creator
Subject
Language
eng
Summary
In December 2005, the US Court of Federal Claims held that National Westminster Bank, PLC, a UK-based multinational bank (NatWest), was not required to apply the formula-based apportionment of interest expense required under domestic US tax law and ruled instead that it was entitled to rely on the properly maintained books and records of its US branch in computing its business profits. In its third decision in the continuing tax dispute, the court provided some valuable guidance on the practical application of the "business profits" article in most tax treaties
Citation source
In: Tax planning international review. - London. - Vol. 33 (2006),
http://library.link/vocab/creatorName
  • Tremblay, R.G
  • Tilak, H
  • Milet, M
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • case law
  • business profits
  • foreign bank
Label
U.S. court rejects formula apportionment in computing business profits of a foreign bank branch
Instantiates
Publication
Label
U.S. court rejects formula apportionment in computing business profits of a foreign bank branch
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...