Bloomberg Law Quotes Charles Plambeck on 3M Winning Transfer Pricing Disputes with the IRS

When the US Tax Court formally wiped out 3M Co.'s contested $4.85 million-plus tax bill this week, it capped off a legal victory for the company that practitioners say could be replicated by other multinationals locked in transfer pricing disputes with the IRS.

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Charles Plambeck, Of Counsel at Caplin & Drysdale, said lawmakers at some point will need to address the broader implications of the 3M decision’s ruling on Section 482 and the blocked-income regulation.

“At a fundamental level, it seems impossible that foreign law can negate US laws applied to US persons. Equally, foreign law is unquestionably a market factor that bears on the amount of income upon which tax is properly levied,” he said, in an email. “At the moment the law remains unsettled between these poles.”

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