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Recent Sixth Circuit Decision in Ohio State University v. Redbubble, Inc. May Burst the Bubble for Online Marketplaces' Defenses of Non-Infringement

Client Alert | less than 1 min read | 05.19.21

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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....