Denmark Can't Be Countersued In $2.8B Tax Fight, Court Told

Law360 (August 20, 2019, 6:48 PM EDT) -- A group of U.S. pension plans targeted by the Danish tax authority in a $2.8 billion refund suit cannot countersue the authority for denying tax refund applications, the agency has told a New York federal court.

In a response filed Monday to counterclaims filed by the pension plans, the Danish authority asked the court to reject claims that its denial of withholding tax refunds for dividends paid on stocks that the authority says the plans never owned violated the United States-Denmark tax treaty. A foreign government agency, the authority argued, cannot be sued in a U.S. court for official acts....

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