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Whirlpool’s Foreign Income Tax Appeal Rejected by Sixth Circuit

Dec. 7, 2021, 12:50 AM

Whirlpool Corp. must pay taxes on more than $45 million in income earned by a Luxembourg subsidiary that sold refrigerators and washing machines to Whirlpool’s U.S. and Mexican operations, a Sixth Circuit panel ruled.

The case divided a three-judge panel of the U.S. Court of Appeals for the Sixth Circuit, with the majority ruling that money earned by the subsidiary qualified as foreign base company sales income under tax code Section 954(d)(2). Under that part of the tax code, the American parent company is taxed directly on foreign base company sales income.

The Monday ruling is a ...

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