3M Company v Commissioner of Internal Revenue: JUDGMENT
Case Information
- Court: United States Tax Court
- Case No: 160 T.C. No. 3, Docket No. 5816-13
- Applicant: 3M Company and Subsidiaries
- Defendant: Commissioner of Internal Revenue
- Judgment Date: 9 February 2023
This case involved the 3M Company and its subsidiaries (collectively referred to as the “3M consolidated group”) disputing a section 482 adjustment made by the Commissioner of Internal Revenue. The dispute focused on the income taxIncome Tax is a direct levy imposed by governments on the income generated by individuals, corporations, and other entities within a specific jurisdiction. It serves as a major source of revenue for governments and funds various public expenditures, such as infrastructure projects, healthcare, education, national security, and welfare programs. The tax is generally calculated as a percentage of the taxable... treatment of intellectual propertyIntellectual Property (IP) refers to creations of the mind, including inventions, literary and artistic works, symbols, names, images, and designs used in commerce. It grants creators exclusive legal rights to use and exploit their work, ensuring protection against unauthorised use or reproduction. These rights are critical in fostering innovation and creativity while providing economic value to individuals and organisations. IP... (IPIntellectual Property (IP) refers to creations of the mind, including inventions, literary and artistic works, symbols, names, images, and designs used in commerce. It grants creators exclusive legal rights to use and exploit their work, ensuring protection against unauthorised use or reproduction. These rights are critical in fostering innovation and creativity while providing economic value to individuals and organisations. IP...) transactions between 3M’s U.S. subsidiaries and its Brazilian subsidiary, 3M do Brasil Ltda (3M Brazil), for the tax year 2006.