State immunity — Jurisdictional immunity — State corporation — United States Foreign Sovereign Immunities Act 1976 — Exceptions to immunity — Pre-existing treaty exception — Whether waiver of immunity contained in bilateral treaty pre-empting later grant of sovereign immunity under the Act — Waiver — Foreign arbitration proceedings between State corporation and third party concerning related dispute — State corporation obtaining judgment in United States court confirming arbitral award — Whether constituting an implicit waiver of immunity — Asserting judgment confirming arbitral award as set off — Whether constituting an implicit waiver of immunity — Commercial activity exception — Requirement of sufficient nexus between case and the United States — Whether sufficient that subsidiary of State corporation doing business in the United States — Requirement of direct effect in the United States — Seizure of vessel abroad by State corporation causing owner to default on bank loan — Whether financial loss suffered by bank as a result of seizure constituting a direct effect

Relationship of international law and municipal law — Treaties — Effect in municipal law — Whether treaty provision a waiver of immunity

Treaties — Effect in municipal law — State immunity — Treaty provision as waiver of immunity — France-United States Convention of Establishment, Protocol and Declaration, 1959, Articles V and XIV — The law of the United States