FedEx, IRS Spar Over Loper Bright’s Effect on Tax Enforcement

The IRS and FedEx Corp. both continued to tell a federal court in Tennessee that the end of the Chevron deference backs their arguments in a dispute over whether the shipping giant overpaid taxes on its overseas income.

The government and shipping giant, which filed their briefs Aug. 9 in the US District Court for the Western District of Tennessee, have been at loggerheads over the interplay of Sections 959, 960, and 965 of the tax code and the IRS’s interpretation of them.

Those sections deal with the treatment of foreign income and were impacted by the Treasury Department’s ...