The Sixth Circuit's Whirlpool Opinion - What's the Impact? Ruling disregards regulatory manufacturing exception but preserves right to rely on regulations in applying branch rule.

Authors :: Yoder, Lowell
Noren, David
Haxton, Britt
Source :: Tax Executive. July-August, 2022, Vol. 74 Issue 4, p34, 7 p.
Publication Year :: 2022
Abstract: The US Court of Appeals for the Sixth Circuit issued a majority opinion in Whirlpool Financial Corporation & Consolidated Subsidiaries v. Commissioner (1) that disregards the regulatory manufacturing exception to [...]

Subjects :: Manufacturing industry -- Taxation
Tax exemption -- Laws, regulations and rules
Controlled foreign corporations -- Taxation
Foreign source income taxation -- Laws, regulations and rules
Branches (Business enterprises) -- Taxation
Whirlpool Financial Corp. v. Commissioner (19 F. 4th 944 (6th Cir. 2021))
Government regulation
Internal Revenue Code (I.R.C. 954)

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