8th Circ.'s Ruling For 3M 'Makes No Sense,' Gov't Says

By Molly Moses · January 29, 2026, 5:51 PM EST

The Eighth Circuit's ruling that Brazilian law prevented the IRS from reallocating income to 3M from its subsidiary in that country "makes no sense" because the law limits only royalties, not...

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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