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24 paź 2024 · In 3M, the taxpayer is challenging the so-called blocked income regulation in Reg. 1.482-1 (h). The Tax Court narrowly upheld the regulation, in large part relying on Chevron deference, prompting 3M to appeal to the US Court of Appeals for the Eighth Circuit. Meanwhile, Abbott Laboratories is challenging the rules for allocating stock-based ...
24 lut 2023 · The U.S. Tax Court recently ruled in favor of the IRS in a major transfer pricing case involving 3M (3M Co. v. Commissioner, 160 T.C. 3). The case is significant due to its broader impact on transfer pricing allocations and uncertain tax positions (UTPs) with respect to countries that impose foreign restrictions on royalties, including China ...
31 paź 2023 · In an effort to limit its liability, 3M employed a bankruptcy strategy known as the “Texas Two-Step,” originating from Texas’s divisive merger statute. The statute allows companies to split into two separate entities, effectively transferring liability to just one of them while insulating the other.
5 gru 2023 · On August 29th, 2023, 3M announced a wide-ranging $6 billion settlement reached with plaintiffs' counsel meant to resolve pending and future litigation related to Combat Arms Earplugs produced by its subsidiary Aearo Technologies.
6 lut 2023 · Yesterday, February 9, 2023, the Tax Court finally issued its ‘split’ decision regarding the 3M “blocked income” issue (formally, a decision regarding the validity of the Treasury Regulation regarding foreign legal restrictions).
28 maj 2021 · Petitta v. 3M Company, No. 19-2932 (8th Cir. 2021) Annotate this Case. Justia Opinion Summary. The Eighth Circuit reversed and vacated the district court's permanent injunction enjoining plaintiff from litigating claims against 3M in Texas state court, where he had filed suit three years earlier.
18 paź 2023 · Get the latest 3M earplug lawsuit updates. Thousands of military service members have sued 3M, claiming the earplugs were defective and led to hearing issues.
