The Eighth Circuit should stop the IRS from reallocating almost $23.7 million of
3M challenged a $4.8 million notice of deficiency issued by the IRS after it allocated more than $23 million in additional income under IRC Section 482 to reflect the arm’s-length compensation the agency says 3M do Brasil Ltda. should’ve paid its parent for intellectual property. The company appeals a US Tax Court ruling ...
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