Supreme Court Declines to Hear Whirlpool’s Foreign Income Dispute

The Supreme Court declined to take up appliance manufacturer Whirlpool’s long-running dispute with the IRS concerning taxes on $45 million in income made by a Luxembourg subsidiary.

Whirlpool Financial Corp. petitioned the high court in June, seeking review of a 2021 ruling from the US Court of Appeals for the Sixth Circuit. The company argues that the appeals court inappropriately disregarded Treasury regulations when it sided with the IRS in holding that the company owed taxes on the foreign income.

The dispute concerns Whirlpool’s controlled foreign corporations, wherein US shareholders own a majority of the foreign company’s stock, as ...