O’Connor v. United States

 
DOCKET NO.
85-558; 85-559; 85-560
OP. BELOW
SUBJECT
Tax
AUTHOR
Scalia

Question(s) Presented

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.”

Holding

“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.”