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When Economic Reality Meets Legal Reality: NEW Lessons from 3M
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When Economic Reality Meets Legal Reality: NEW Lessons from 3M
The Eighth Circuit’s decision in 3M Co. v. Commissioner has officially joined the ranks of cases that every transfer pricing practitioner will be citing for years to come. At its heart, this case asks a surprisingly fundamental question: Can the IRS tax income that a company was legally prohibited from receiving? In 3M’s case, Brazil said “no,” and the Eighth Circuit agreed. A Quick Refresher: What Happened 3M’s Brazilian subsidiary licensed…
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