FEDEX CORPORATION and SUBSIDIARIES v. United States of America
Case Number:
2:20-cv-02794
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April 26, 2024
FedEx Calls Gov't Arguments On Tax Credits Contradictory
The federal government advanced contradictory arguments in FedEx's $84.6 million foreign tax credits dispute with the Internal Revenue Service, the package delivery giant said in a filing in Tennessee federal court.
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April 12, 2024
FedEx Not Entitled To $84.6M In Tax Credit Dispute, US Says
FedEx is not entitled to a judgment of nearly $84.6 million that the company requested in March for its foreign tax credit dispute, the federal government said Friday in a Tennessee federal court filing.
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March 11, 2024
FedEx Says Gov't Can't Redo $85M Foreign Tax Credit Case
The U.S. government is trying to relitigate a Tennessee federal court's decision that sided with FedEx in a foreign tax credit dispute, the company said in asking the court to rule that it's entitled to a refund of nearly $85 million.
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July 07, 2023
Top International Tax Cases In 1st Half Of 2023
The Internal Revenue Service scored a victory early this year when a divided U.S. Tax Court upheld contested transfer pricing regulations, followed by a defeat in Tennessee, where a federal judge struck down rules for the 2017 tax overhaul’s repatriation provision. Here, Law360 breaks down major international tax decisions issued during the first half of 2023.
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April 03, 2023
FedEx Wins Nix Of Transition Tax Reg In $89M Refund Fight
A Tennessee federal judge struck down a Treasury regulation on the transition tax that the government cited in denying FedEx $89 million in tax credits on overseas income, finding the rule contradicted the plain language of the law.
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September 12, 2022
FedEx's Tax Credits Not Allowed Under TCJA, US Says
FedEx cannot take tax credits for offshore income that already offsets its tax liability because the 2017 federal overhaul's transition tax doesn't allow it, the U.S. told a Tennessee federal court hearing the company's $89.15 million dispute against the IRS.
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July 26, 2022
FedEx Calls TCJA Transition Tax Regs Invalid
FedEx Corp. urged a Tennessee federal court to invalidate final regulations that deny foreign tax credits on offshore income targeted by the 2017 federal overhaul's transition tax, contending that statutory provisions authorize the credits that are denied under the rules.
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July 15, 2022
International Tax Cases To Watch In The Second Half Of 2022
Tax practitioners will have several high-stakes cases to track during the second half of 2022, including disputes brought by major U.S. multinational corporations that have accused the federal government of overstepping when writing regulations and reallocating foreign profits. Here, Law360 looks at eight key international tax cases to follow during the second half of 2022.
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January 03, 2022
International Tax Cases To Watch In 2022
Courts will continue grappling this year with high-stakes cases brought by major U.S. multinationals that have accused federal tax authorities of overstepping, with disputes including FedEx's challenge to repatriation regulations and Facebook's fight against multibillion-dollar adjustments to its tax bill. Here, Law360 looks at eight key international tax cases to follow in 2022.
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July 09, 2021
4 International Tax Cases To Watch In 2021's 2nd Half
The second half of 2021 could bring important developments in tax litigation involving major U.S. multinationals, including Coca-Cola’s fight against its $3.3 billion transfer pricing loss and FedEx’s claim that the U.S. Treasury Department overstepped its authority in repatriation regulations. Here, Law360 looks at four key international tax cases to follow during the rest of the year.