Bloomberg Tax
Free Newsletter Sign Up
Bloomberg Tax
Welcome
Go
Free Newsletter Sign Up

Whirlpool Seeks High Court Review of IRS Foreign Income Dispute

June 30, 2022, 10:39 PM

Appliance manufacturer Whirlpool asked the US Supreme Court to weigh in on a long-running dispute with the IRS over $45 million in income made by a Luxembourg subsidiary, arguing that an appeals court inappropriately disregarded Treasury regulations when it sided with the IRS.

Whirlpool Financial Corp., in a cert petition filed Thursday, called for the high court to review its 2021 loss in the US Court of Appeals for the Sixth Circuit. The company argued the Sixth Circuit erred by holding that a tax statute explicitly conditioned on the Treasury Department issuing regulations could be enforced without consulting the regulations, ...