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

Case No. 14-cv-01593 (CRC).

139 F.Supp.3d 214 (2015)

STARR INTERNATIONAL COMPANY, INC., Plaintiff, v. UNITED STATES of America, Defendant. United States of America, Counterclaim-Plaintiff, v. Tarr International Company, Inc., Counterclaim-Defendant.

United States District Court, District of Columbia.

Signed September 18, 2015.

Attorney(s) appearing for the Case

Andrew Todd Wise , Thomas Edward Zehnle , Kevin M. Downing , Miller & Chevalier, Chartered, Washington, DC, for Plaintiff/Counterclaim-Defendant.

Dennis Michael Donohue , William Edward Farrior , U.S. Department of Justice, Washington, DC, for Defendant/Counterclaim-Plaintiff.

MEMORANDUM OPINION

Foreign corporations owe U.S. federal income tax on dividend income received from sources within the United States. If that income is insufficiently connected to a foreign corporation's business activity in...

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