FEDEX CORPORATION and SUBSIDIARIES v. United States of America

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Case Number:

2:20-cv-02794

Court:

Tennessee Western

Nature of Suit:

Taxes

Judge:

Samuel H. Mays, Jr

Firms

Companies

Sectors & Industries:

  1. August 12, 2024

    FedEx Misreads Chevron Ruling In $85M Tax Dispute, US Says

    FedEx wrongly believes the recent U.S. Supreme Court decision overturning the Chevron doctrine precludes the U.S. Treasury Department from promulgating regulations to stop tax cheats and prevent FedEx from claiming $84.6 million in tax credits, the U.S. government told a Tennessee federal court.

  2. August 05, 2024

    FedEx Asserts Chevron Ruling Supports $84.6M Refund

    The U.S. Supreme Court's recent rejection of the Chevron doctrine entitles FedEx to an $84.6 million tax refund by taking credits for foreign taxes it paid on offset earnings when repatriating overseas income, the package delivery giant told a Tennessee federal court.

  3. April 26, 2024

    FedEx Calls Gov't Arguments On Tax Credits Contradictory

    The federal government advanced contradictory arguments in FedEx's $84.6 million foreign tax credits dispute with the Internal Revenue Service, the package delivery giant said in a filing in Tennessee federal court.

  4. April 12, 2024

    FedEx Not Entitled To $84.6M In Tax Credit Dispute, US Says

    FedEx is not entitled to a judgment of nearly $84.6 million that the company requested in March for its foreign tax credit dispute, the federal government said Friday in a Tennessee federal court filing.

  5. March 11, 2024

    FedEx Says Gov't Can't Redo $85M Foreign Tax Credit Case

    The U.S. government is trying to relitigate a Tennessee federal court's decision that sided with FedEx in a foreign tax credit dispute, the company said in asking the court to rule that it's entitled to a refund of nearly $85 million.

  6. July 07, 2023

    Top International Tax Cases In 1st Half Of 2023

    The Internal Revenue Service scored a victory early this year when a divided U.S. Tax Court upheld contested transfer pricing regulations, followed by a defeat in Tennessee, where a federal judge struck down rules for the 2017 tax overhaul’s repatriation provision. Here, Law360 breaks down major international tax decisions issued during the first half of 2023.

  7. April 03, 2023

    FedEx Wins Nix Of Transition Tax Reg In $89M Refund Fight

    A Tennessee federal judge struck down a Treasury regulation on the transition tax that the government cited in denying FedEx $89 million in tax credits on overseas income, finding the rule contradicted the plain language of the law.

  8. September 12, 2022

    FedEx's Tax Credits Not Allowed Under TCJA, US Says

    FedEx cannot take tax credits for offshore income that already offsets its tax liability because the 2017 federal overhaul's transition tax doesn't allow it, the U.S. told a Tennessee federal court hearing the company's $89.15 million dispute against the IRS.

  9. July 26, 2022

    FedEx Calls TCJA Transition Tax Regs Invalid

    FedEx Corp. urged a Tennessee federal court to invalidate final regulations that deny foreign tax credits on offshore income targeted by the 2017 federal overhaul's transition tax, contending that statutory provisions authorize the credits that are denied under the rules.

  10. July 15, 2022

    International Tax Cases To Watch In The Second Half Of 2022

    Tax practitioners will have several high-stakes cases to track during the second half of 2022, including disputes brought by major U.S. multinational corporations that have accused the federal government of overstepping when writing regulations and reallocating foreign profits. Here, Law360 looks at eight key international tax cases to follow during the second half of 2022.