Unionbancal Corporation - Page 28




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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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