Legal Opinion
National Westminster Bank, PLC v. United States
Court of Appeals for the Federal Circuit
Decided January 15, 2008No. 2007-5028PublishedCited by 16 opinions
1Opinion of the Court
GAJARSA, Circuit Judge.
This is a tax refund action brought by taxpayer National Westminster Bank PLC (“NatWest”), a United Kingdom corporation, for the tax years 1981-1987. The Government appeals from the judgment of the United States Court of Federal Claims (“trial court” or “court”) that NatWest is entitled to a refund of $65,723,053 plus interest for the tax years at issue. Central to the trial court’s judgment is the issue of whether the application of Treasury Regulation § 1.882-5 is consistent with the United States’ obligations under Article 7 of the Convention for the Avoidance of…
2Cases cited17 opinions
- Sumitomo Shoji America, Inc. v. AvaglianoSupreme Court of the United States · 1982
- Kolovrat v. OregonSupreme Court of the United States · 1961
- United States v. StuartSupreme Court of the United States · 1989
- Winstar Corp. v. United StatesCourt of Appeals for the Federal Circuit · 1995
- In Re RossSupreme Court of the United States · 1891
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3Cited by16 opinions
- Potter v. District of ColumbiaCourt of Appeals for the D.C. Circuit · 2009
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- McManus v. United StatesUnited States Court of Federal Claims · 2017
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