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 benefits on dividends received from AIG for that year, which is provided for under the U.S.-Swiss treaty. The IRS denied the request for benefits for 2007, but subsequently issued a refund for 2008. Starr filed suit, claiming that the IRS abused its discretion...