May 14, 2026
The U.S. government urged the Sixth Circuit to reverse a Tennessee federal court's decision that invalidated foreign tax credit regulations and allowed FedEx an $89 million refund, arguing that the rules reflect Congress' intent to prevent windfalls under the 2017 tax overhaul.
March 24, 2026
FedEx is entitled to an $89 million tax refund because the U.S. Department of the Treasury lacked the authority to issue regulations disallowing foreign tax credits for offset earnings, the company told the Sixth Circuit, asking the court to uphold a lower court ruling.
January 08, 2026
The Sixth Circuit should vacate a judgment that allowed FedEx an $89 million refund by discarding a regulation preventing companies from claiming foreign tax credits on earnings offset by losses, which aren't taxed in the U.S., the government said in an opening brief.