National Westminster Bank, PLC v. United States

OPINION ON SUMMARY JUDGMENT

FIRESTONE, Judge.

This case comes before the court on a motion for summary judgment by the plaintiff, National Westminster Bank PLC (“plaintiff” or “NatWest”), a United Kingdom (“U.K.”) bank. The plaintiff argues that under a treaty between the United States and the United Kingdom, it is entitled to a refund of some of its federal income tax on the income of its branches located in the United States. The defendant, the United States (“government” or “United States”) argues that there are genuine issues of material fact that preclude summary judgment. For the…