Albemarle Corp. & Subsidiaries v. United States

ON PETITION FOR REHEARING

BRYSON, Circuit Judge.

Albemarle Corporation and Subsidiaries (“Albemarle”) petitions for rehearing of this court’s August 13, 2015, decision on its appeal from the Court of Federal Claims. For the reasons set forth below, we deny the petition.

1. In its petition, Albemarle first argues that the decision in this case conflicts with this court’s recent decision in Salem Financial, Inc. v. United States, 786 F.3d 932 (Fed.Cir.2015). Albemarle’s argument is not really based on the Salem case, which says nothing about when foreign taxes accrue, but instead is based on the…