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U.S. Court Holds Denial of Discretionary Tax Treaty Benefits subject to Judicial Review

|Treaty Development|United States-Switzerland
United States-Switzerland

On 18 September 2015, the U.S. District Court for the District of Columbia issued a memorandum opinion that the denial of discretionary tax treaty benefits may be subject to judicial review.

The case involved Swiss-domiciled Starr International Company (Starr), once the largest shareholder of American International Group (AIG). In 2007, Starr petitioned the IRS for discretionary treaty benefi…

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