3M Company v. Commissioner of Internal Revenue

  1. May 31, 2024

    3M Tells 8th Circ. IRS Used Invalid Regs For $24M Allocation

    Multinational conglomerate 3M reiterated Friday its bid for the Eighth Circuit to reverse a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from the company's Brazilian affiliate, arguing the agency's adjustment relied on substantively invalid regulations.

  2. May 14, 2024

    Law Prof Comes To Treasury's Aid In 3M Transfer Pricing Fight

    The U.S. Department of the Treasury did not act arbitrarily when it wrote transfer pricing regulations that allowed the government to disregard foreign legal restrictions on royalty payments when allocating income to 3M from an affiliate, a law professor told the Eighth Circuit on Tuesday.

  3. May 11, 2024

    Gov't Urges 8th Circ. To Uphold 3M's $24M Pricing Adjustment

    The U.S. government asked the Eighth Circuit to uphold a U.S. Tax Court decision allowing the IRS to allocate nearly $24 million from 3M's Brazilian affiliate, arguing the company's appeal involves misplaced reliance on a U.S. Supreme Court decision.

  4. February 16, 2024

    Manufacturers Back 3M In 8th Circ. Transfer Pricing Case

    The National Association of Manufacturers joined the chorus of business groups supporting 3M, asking the Eighth Circuit to throw out transfer pricing regulations that allow the Internal Revenue Service to reallocate income to U.S. group members even when foreign laws prohibit outbound payments.

  5. February 15, 2024

    Chamber, Others Back 3M In Transfer Pricing Appeal

    The Eighth Circuit should set aside transfer pricing regulations from the U.S. Treasury Department that reallocated $23 million of income from 3M's Brazilian affiliate to the parent company, three trade associations told the court in amicus briefs.

  6. February 14, 2024

    Tech Group Backs 3M In 8th Circ. Transfer Pricing Appeal

    A tax group representing multinational tech companies urged the Eighth Circuit to overturn a U.S. Tax Court ruling that found 3M Co. owed taxes stemming from an additional $23 million in income reallocated from its Brazilian affiliate, saying the decision wrongly upheld transfer pricing regulations that were improperly enacted.

  7. January 03, 2024

    8th Circ. To Weigh In On 3M's Fight Over Income Allocations

    The Eighth Circuit will hear 3M's challenge to a U.S. Tax Court ruling that sustained a $23 million income reallocation from the company's Brazilian affiliate under contested regulations.