Whirlpool Seeks Rehearing on $45 Million Foreign Income Tax Spat

Whirlpool Corp. is disputing a ruling from last December that it must pay taxes on over $45 million made by a Luxembourg subsidiary, arguing that an appeals court improperly read a condition under the tax code relating to foreign income.

A U.S. Court of Appeals for the Sixth Circuit panel ruled for the IRS in December, finding that income made from Whirlpool’s Luxembourg subsidiary selling appliances to the company’s U.S. and Mexico operations were taxable. Dissent came from Judge John B. Nalbandian, raising questions over whether the subsidiary qualified for an exception to the foreign based sales income because ...