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STARR INTERN. COMPANY, INC. v. U.S.

No. 17-5238.

910 F.3d 527 (2018)

STARR INTERNATIONAL COMPANY, INC., Appellant v. UNITED STATES of America, et al., Appellees.

United States Court of Appeals, District of Columbia Circuit.

Decided December 7, 2018.

Attorney(s) appearing for the Case

Rajiv Madan , Washington, DC, argued the cause for appellant. With him on the briefs were Christopher P. Bowers , Nathan P. Wacker , and Caroline Van Zile .

Richard Caldarone , Attorney, U.S. Department of Justice, argued the cause for appellees. With him on the brief were Travis A. Greaves , Deputy Assistant Attorney General, and Gilbert S. Rothenberg and Richard Farber , Attorneys. Judith A. Hagley , Attorney, entered an appearance.

Before: Henderson and Millett, Circuit Judges, and Edwards, Senior Circuit Judge.

Dividends paid by U.S. corporations and received by foreign shareholders are generally subject to a 30 percent withholding tax. See 26 U.S.C. §§ 881(a)(1), 1442(a). Bilateral tax treaties between the United States and other nations reduce this tax rate to encourage cross-border investments and allow...

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