In the Headlines
December 23, 2025
Top International Tax Cases of 2025
Law360
Tax attorney Joshua Odintz was cited in a Law360 article highlighting the year's most significant international tax cases, including major disputes involving transfer pricing, cross-border withholding and information reporting regimes. The article also examined the U.S. Court of Appeals for the Eighth Circuit's decision in 3M, which applied the U.S. Supreme Court's Loper Bright framework to reject IRS regulations used to reallocate income from a Brazilian subsidiary where local law restricted the payment of royalties. Mr. Odintz noted that the ruling narrows when the IRS can invoke the commensurate with income standard.
"It would have been legally impossible for 3M to pay the royalty in the amount that the U.S. claims should have been paid," he said.
READ: Top International Tax Cases of 2025 (Subscription required)
"It would have been legally impossible for 3M to pay the royalty in the amount that the U.S. claims should have been paid," he said.
READ: Top International Tax Cases of 2025 (Subscription required)