- 28 - Commissioner, 104 T.C. 384, 390 (1995). Moreover, a Treasury regulation “is not invalid simply because the statutory language will support a contrary interpretation.” United States v. Vogel Fertilizer Co., 455 U.S. 16, 26 (1982). The question is “not whether the Treasury Regulation represents the best interpretation of the statute, but whether it represents a reasonable one.” Atlantic Mut. Ins. Co. v. Commissioner, 523 U.S. 382, 389 (1988). As discussed above, the Temporary Regulation is a reasonable interpretation of section 267(f). II. The Temporary Regulation Does Not Violate the United States-United Kingdom Income Tax Treaty Petitioner argues that the Temporary Regulation is inconsistent with Article 24, paragraph (5) of the U.S.-U.K. treaty, which provides as follows: Enterprises of a Contracting State, the capital of which is wholly or partly owned or controlled, directly or indirectly, by one or more residents of the other Contracting State, shall not be subjected in the first- mentioned Contracting State to any taxation or any requirement connected therewith which is other or more burdensome than the taxation and connected requirements to which other similar enterprises of the first-mentioned State are or may be subjected. Neither section 267(f) nor the Temporary Regulation discriminates between United Kingdom taxpayers and U.S. taxpayers, or between U.S. taxpayers owned by United Kingdom interests and U.S. taxpayers not owned by United KingdomPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 Next
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