Whether § 2 of Article XV of the Agreement in Implementation of Article III of the Panama Canal Treaty “constitutes an express exemption of . . . Commission salaries from both Panamanian and United States taxation.”
“The petitioners contend that § 2 of this Article constitutes an express exemption of their Commission salaries from both Panamanian and United States taxation. The Claims Court agreed, but was reversed by a five-judge panel of the Federal Circuit. We agree with the Federal Circuit.”