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WHIRLPOOL FIN. CORP. v. COMM'R OF INTERNAL REVENUE

Nos. 20-1899/1900.

19 F.4th 944 (2021)

WHIRLPOOL FINANCIAL CORPORATION; Consolidated Subsidiaries, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Sixth Circuit.

Decided and Filed: December 6, 2021.

Attorney(s) appearing for the Case

ARGUED: Gregory G. Garre , LATHAM & WATKINS LLP, Washington, D.C., for Appellants. Judith A. Hagley , UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee. ON BRIEF: Mark A. Oates , Robert H. Albaral , A. Duane Webber , Summer M. Austin , Joseph B. Judkins , Meerah Kim , Cameron C. Reilly , BAKER & MCKENZIE LLP, Chicago, Illinois, Rodney H. Standage , WHIRLPOOL CORPORATION, Chicago, Illinois, for Appellants. Judith A. Hagley , Francesca Ugolini , Arthur T. Catterall , UNITED STATES DEPARTMENT OF JUSTICE, Washington, D.C., for Appellee.

KETHLEDGE, Circuit Judge, delivered the opinion of the court in which NORRIS, Circuit Judge, joined. NALBANDIAN, Circuit Judge (pp. 954-63), delivered a separate dissenting opinion.

OPINION

A subsidiary of Whirlpool Corporation with a single part-time employee in Luxembourg sold refrigerators and washing machines to Whirlpool in a series of complicated transactions. By means of a 2007 corporate restructuring, neither the Luxembourgian subsidiary nor Whirlpool itself paid any taxes on the...

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