3M Company v. Commissioner of Internal Revenue
Case Number:
23-3772
Court:
Nature of Suit:
Companies
- 3M Co.
- National Association of Manufacturers
- National Foreign Trade Council
- National Taxpayers Union
- Silicon Valley Tax Directors Group
Sectors & Industries:
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February 20, 2026
Full 8th Circ. Won't Revisit 3M's Win Against IRS
The full Eighth Circuit declined to rethink a panel's ruling that held the Internal Revenue Service lacked the statutory authority to allocate nearly $24 million in royalty payments that 3M Co. said it was blocked from receiving under Brazilian law.
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February 18, 2026
8th Circ. Misread Law In 3M's $24M Case, Tax Prof Says
The Eighth Circuit misconstrued the statute underpinning transfer pricing regulations when it blocked the IRS from allocating nearly $24 million of 3M Co.'s Brazilian income, a tax professor said in backing the agency's bid for a rehearing by the full court.
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January 29, 2026
8th Circ.'s Ruling For 3M 'Makes No Sense,' Gov't Says
The Eighth Circuit's ruling that Brazilian law prevented the IRS from reallocating income to 3M from its subsidiary in that country "makes no sense" because the law limits only royalties, not other forms of income, the government argued Thursday in seeking a rehearing by the full court.
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December 23, 2025
Top International Tax Cases Of 2025
Government tax administrations came up short in some of the biggest international cases decided this year, including Denmark's challenge to a British trader it accused of deceiving the tax authority into paying thousands of improper refunds. Here, Law360 examines seven of the year's top international tax cases.
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October 01, 2025
8th Circ. Reverses IRS Win In 3M Transfer Pricing Case
The Eighth Circuit reversed a U.S. Tax Court ruling Wednesday that backed the Internal Revenue Service's decision to reallocate nearly $24 million of 3M Co.'s Brazilian income, holding that the transfer pricing regulations underlying the adjustment are invalid.
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July 03, 2025
Top International Tax Cases To Watch In 2nd Half Of 2025
Major multinational corporations such as 3M and Coca-Cola are expected to continue litigating high-stakes international tax cases in the second half of 2025, including disputes that could test the application of the U.S. Supreme Court's ruling that gutted judicial deference to agencies. Here, Law360 looks at seven key cases to follow the rest of the year.
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January 01, 2025
Top International Tax Cases To Watch In 2025
Major multinational corporations such as 3M and Coca-Cola will continue to litigate high-stakes international tax cases during 2025, including transfer pricing disputes with billions of dollars on the line and fights against regulations that allegedly exceed the government's authority. Here, Law360 looks at six key international tax cases to follow in the new year.
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January 01, 2025
Top Federal Tax Cases To Watch In 2025
Over the next year, tax practitioners will be closely monitoring suits that challenge the IRS' use of the economic substance doctrine, take advantage of the U.S. Supreme Court's landmark decision curbing federal agencies' regulatory authority and dispute the government's handling of worker retention credits. Here, Law360 looks at key federal tax cases to follow in 2025.
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October 22, 2024
8th Circ. Judge Presses IRS On 3M Transfer Pricing Tax Ruling
An Eighth Circuit judge cast doubt during oral arguments Tuesday on the government's interpretation of regulations the IRS relied on to reallocate almost $24 million of income to 3M from its Brazilian affiliate that was subject to legal restrictions on royalty payments.
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October 09, 2024
3M Tax Ruling Must Fall Post-Chevron, Chamber Tells 8th Circ.
The U.S. Supreme Court's ending of the Chevron doctrine calls for overturning a U.S. Tax Court ruling that let the IRS allocate $24 million of income to multinational conglomerate 3M from a Brazilian affiliate, the U.S. Chamber of Commerce told the Eighth Circuit on Wednesday.