3M Company v Commissioner of Internal Revenue: Judgment

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 tax treatment of intellectual property (IP) transactions between 3M's U.S. subsidiaries and its Brazilian subsidiary, 3M do Brasil Ltda (3M Brazil), for the tax year 2006.

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