Art. 10(3) of the 2001 United States-United Kingdom income tax treaty. Art. 10(3)(a) of the US-UK treaty provides that dividends are exempt from tax in the source contracting state if the beneficial owner is a company resident in the other contracting state that has owned shares representing 80% or more of the voting power of the company paying the dividends for a 12-month period ending on the date the dividends are declared and certain other requirements are met. The Treasury Department Technical Explanation to Art. 10(3)(a) states that the shares of the 80% owned subsidiary must be "owned directly". The...