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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 Kingdom
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