Whirlpool’s Subpart F Position Aligned with Congress Inten | McDermott

Whirlpool’s Subpart F Position Was Consistent With Congressional Inten


Lowell Yoder, David Noren, Jonathan Lockhart and Elizabeth Lu author an article discusses why the Tax Court’s reliance on the Subpart F legislative history to support its decision was incorrect and explains that Congress intended the income derived in Whirlpool’s Maquiladora supply chain structure to not be Subpart F income.