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U.S. Court Upholds IRS Application of Principal Purpose Test for Discretionary Treaty Benefits

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

On 14 August 2017, the U.S. District Court for the District of Columbia found in favor of the IRS in a summary judgment concerning whether the IRS was justified in not granting discretionary benefits under the Swiss-U.S. tax treaty. The case involved Swiss-domiciled Starr International Company, Inc. (Starr), once the largest shareholder of American International Group (AIG). Starr was originall…

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