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Declaratory Judgment Actions Examined

Client Alert | less than 1 min read | 05.08.06

A declaratory judgment action is sometimes the best way to resolve a contract dispute, but you must know how to use it. In “Declaratory Judgment Actions--An Effective Tool for Serious Situations," in the American Bar Association's Spring 2006 publication of The Procurement Lawyer, (http://www.crowell.com/pdf/Newsroom/Haile-Claybrook_procureSpr06.pdf) Rick Claybrook and Chris Haile of C&M examine the use of these special actions, providing insight into when they are most effective and warning of some common pitfalls to avoid.

Insights

Client Alert | 3 min read | 10.07.25

Blocking the Blocked Income Rules? Loper Bright’s influence over the Eighth Circuit’s 3M decision.

On October 1, 2025, the Eighth Circuit decided 3M Co. v. Commissioner in the taxpayer’s favor, based on its application of Loper Bright. The question presented in the case was whether the IRS had the authority to reallocate royalty income to a U.S. parent company that its foreign subsidiary was prohibited from paying under foreign law. The court held that the best interpretation of the governing statute did not permit the IRS’s reallocation....