News & Analysis as of

Regulatory Requirements Internal Revenue Service Tax Refunds

McDermott Will & Schulte

FedEx Defeats Government’s Loper Bright Gambit

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

Fleurinord Law PLLC

The Pros and Cons of Parents Claiming College Students as Dependents

Fleurinord Law PLLC on

As the back-to-school season kicks off and college students begin their fall semester, now is the perfect time to consider the financial implications of your child heading off to college. The decision of whether to claim them...more

McDermott Will & Schulte

IRS (Belatedly) Strikes Back Against FedEx in Ongoing Foreign Tax Credit Case

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

Eversheds Sutherland (US) LLP

An apparent 180 degree turn by the Service with research credit claims

On January 3, 2022, the IRS Office of Chief Counsel released an interim guidance memorandum (the Interim Guidance), along with a set of FAQs, to provide IRS Examining Agents with procedural guidance for applying Field...more

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