Court of Appeals affirms NatWest case – US branch interest rules violate 1975 US-UK income tax treaty The US Court of Appeals for the Federal Circuit has affirmed lower court decisions holding that the US branch interest allocation rules of Treasury Regulation § 1.882-5 violate Art. 7 (Business profits) of the 1975 US-UK Income Tax Treaty in National Westminster Bank PLC v. United States, Docket No. 2007-5028 (15 January 2008). The US Court of Federal Claims had previously ruled in favour of NatWest in three earlier decisions: -   NatWest I, holding that the US branch interest allocation rules of...