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Tax Refunds Appeals Corporate Taxes

McDermott Will & Emery

FedEx Defeats Government’s Loper Bright Gambit

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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

Blank Rome LLP

Supreme Court of Arkansas Allows Corporation to Allocate Interest Expense Incurred to Fund Corporate Spin-off

Blank Rome LLP on

A recent Supreme Court of Arkansas decision has upheld a multistate corporation’s allocation to Arkansas of 100% of its interest expenses from borrowings to fund a spin-off. It also rejected as irrelevant the state’s attempt...more

Blank Rome LLP

Supreme Court of Ohio Affirms Denial of Healthcare Service Provider’s Commercial Activity Tax Refund Claim

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The Supreme Court of Ohio upheld the denial of Total Renal Care, Inc.’s (“TRC”) refund claim of Ohio Commercial Activity Tax (“CAT”) that it paid on services that it performed outside of Ohio. Total Renal Care Inc. v. Harris,...more

Eversheds Sutherland (US) LLP

Court of Appeals Hears Michigan’s Compact Election Cases

The long saga of Michigan's Multistate Tax Compact election continued on Wednesday with oral argument before the Michigan Court of Appeals. A packed courtroom witnessed a 1.5 hour proceeding before an active three-judge...more

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