On February 13, 2025, a Tennessee federal district court handed FedEx Corporation its second win in a refund action involving the application of foreign tax credits to what are known as “offset earnings.”[1] Offset earnings...more
3/13/2025
/ Appeals ,
Chevron Deference ,
Corporate Taxes ,
FedEx ,
Foreign Tax Credits ,
Government Agencies ,
Internal Revenue Code (IRC) ,
IRS ,
Loper Bright Enterprises v Raimondo ,
Offsets ,
Regulatory Requirements ,
SCOTUS ,
Statutory Authority ,
Tax Avoidance ,
Tax Credits ,
Tax Refunds
FedEx Corporation, previously the victor in a closely watched dispute regarding the government’s regulatory attempt to prevent taxpayers from claiming foreign tax credits on offset earnings (131 AFTR 2d 2023-1284 (W.D. Tenn....more