Whirlpool Financial Corp, et al v. CIR

Track this case

Case Number:

20-1899

Court:

Appellate - 6th Circuit

Nature of Suit:

Companies

Sectors & Industries:

  1. 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.

  2. 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.

  3. 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.

  4. 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. 

  5. 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.

  6. 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.

  7. 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.

  8. 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.

  9. 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.

  10. 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.