Whirlpool Financial Corp, et al v. CIR
Case Number:
20-1899
Court:
Nature of Suit:
Companies
Sectors & Industries:
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December 19, 2022
Top International Tax Cases Of 2022
This year, courts weighed in on key transfer pricing topics, including a decision that confirmed the application of contract law to advance pricing agreements and another ruling that took a unique path in finding an arm’s-length division of intercompany profits. Here, Law360 breaks down major international tax decisions issued in 2022.
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January 28, 2022
Industry Groups Ask 6th Circ. To Reconsider Whirlpool Ruling
The Sixth Circuit should reconsider a December ruling that Whirlpool owes taxes on $45 million in income relating to operations that a Luxembourg subsidiary conducted in Mexico, several industry groups told the court.
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January 27, 2022
6th Circ. Urged To Reconsider $45M Foreign Income Case
The Sixth Circuit should reconsider its holding that $45 million in income related to operations a Whirlpool subsidiary conducted in Mexico was foreign base company sales income, because it ignored an exception in Treasury regulations, a manufacturing association said Thursday.
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January 20, 2022
Whirlpool Asks 6th Circ. To Rehear $45M Foreign Income Case
Whirlpool asked the Sixth Circuit on Thursday to reconsider its December decision holding that the company owed taxes for more than $45 million in income relating to operations a Luxembourg subsidiary conducted in Mexico.
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December 22, 2021
Top International Tax Cases Of 2021
Significant rulings in international tax cases during 2021 put European Union and U.S. tax policies to the test while also suggesting an erosion of attorney-client privilege stateside. Here, Law360 examines the top rulings of the year in three distinct areas of international tax.
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December 06, 2021
Whirlpool Owes Tax On $45M Foreign Income, 6th Circ. Says
The Sixth Circuit affirmed in a split decision Monday that Whirlpool owes the Internal Revenue Service taxes on more than $45 million in income generated by a Luxembourg affiliate's sales to a Mexican subsidiary.
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June 03, 2021
Gov't Hits Back At Whirlpool's Play To Scrap Treasury Reg
The U.S. fired back at Whirlpool Corp.'s argument for scrapping a Treasury regulation in the appliance manufacturer's effort to escape taxes on $50 million its Luxembourg affiliate made selling to a Mexican subsidiary.
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February 16, 2021
Whirlpool's $50M Foreign Income Not Taxable, 6th Circ. Told
The U.S. Tax Court incorrectly applied the U.S. Treasury's manufacturing branch rule to determine that Whirlpool owes tax on $50 million in income generated by a Luxembourg affiliate's sales to a Mexican subsidiary, the company told the Sixth Circuit.
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January 22, 2021
Whirlpool's $50M Foreign Income Taxable In US, 6th Circ. Told
The U.S. Tax Court correctly found that Whirlpool generated almost $50 million in additional taxable income through a Luxembourg affiliate's sales and it should have to pay tax on the amount, the U.S. government told the Sixth Circuit Friday.
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November 17, 2020
Whirlpool's $50M Foreign Income Is Not Taxable, 6th Circ. Told
Whirlpool's roughly $50 million in offshore earnings isn't taxable income because it was generated by two foreign affiliates manufacturing different products, the company told the Sixth Circuit Tuesday, urging it to reverse a U.S. Tax Court decision.