Can Taxpayers Eliminate FBCSI Based on Whirlpool? - McDermott Will & Emery

Can Taxpayers Eliminate FBCSI Based on Whirlpool?

Overview


Lowell YoderDavid Noren and Jonathan Lockhart author this article in Tax Notes where they argue that the Sixth Circuit decision in Whirlpool may allow taxpayers to avoid foreign base company sales income through a restructuring by following the court’s own logic and disregarding relevant regulations when the language of the IRC is unambiguous.