The U.S. Supreme Court has refused a request by appliance manufacturer, Whirlpool to review a long-standing case. At issue is the treatment of Whirlpool’s 2009 earnings from its Luxembourg controlled foreign corporation, and whether branch rules applied to the income or U.S. Treasury regulations that taxpayers have relied upon for decades. In a tax blog, Whirlpool attorneys call the case a continuance of “the seemingly never-ending battle over when, if and how to interpret and apply tax regulations, albeit in the context of whether agencies and courts must follow validly promulgated regulations.” The High Court’s rejection of the case only binds the previous ruling by the 6th Circuit. Call or visit our website for more information! www.mjscpa.com/
