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XEROX CORP. v. U.S.

No. 93-5094.

41 F.3d 647 (1994)

XEROX CORPORATION, Plaintiff-Appellant, v. The UNITED STATES, Defendant-Appellee.

United States Court of Appeals, Federal Circuit.

Rehearing Denied February 7, 1995.

Attorney(s) appearing for the Case

H. Stewart Dunn, Jr., Ivins, Phillips and Barker, Washington, DC, argued for plaintiff-appellant. With him on the brief were Michael F. Solomon and Claude B. Stansbury, of counsel.

Thomas J. Clark, Atty., Dept. of Justice, Washington, DC, argued for defendant-appellee. With him on the brief were Michael L. Paup, Acting Asst. Atty. Gen., Gary R. Allen and David English Carmack, Attys.

Before RICH, NEWMAN, and PLAGER, Circuit Judges.

PAULINE NEWMAN, Circuit Judge.

This tax appeal has its origins in the United Kingdom system of corporate and shareholder taxation that was adopted in the Finance Act of 1972. The ensuing changes of tax structure in the United Kingdom resulted in renegotiation of the tax treaty between the United Kingdom and the United States, in order to obtain for United States shareholders the avoidance of double taxation on dividends. This...

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