8th Circ. Misread Law In 3M's $24M Case, Tax Prof Says

By Natalie Olivo · February 18, 2026, 4:02 PM EST

The Eighth Circuit misconstrued the statute underpinning transfer pricing regulations when it blocked the IRS from allocating nearly $24 million of 3M Co.'s Brazilian income, a tax professor said in backing...

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Case Information

Case Title

3M Company v. Commissioner of Internal Revenue

Case Number

23-3772

Court

Appellate - 8th Circuit

Nature of Suit

Agency 

Date Filed

December 29, 2023