FEDEX CORPORATION and SUBSIDIARIES v. United States

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION ) FEDEX CORPORATION AND ) SUBSIDIARIES, ) ) Plaintiff, ) ) v. ) No. 20-cv-2794 ) UNITED STATES OF AMERICA, ) ) Defendant. ) ) ORDER ON CROSS MOTIONS FOR PARTIAL SUMMARY JUDGMENT This is a tax case. Plaintiff FedEx Corporation and Subsidiaries (“FedEx”) argues that the government wrongly denied it certain foreign tax credits and seeks a refund of more than $89 million.1 (ECF No. 1 at PageID 30.) Defendant, the United States, contends that the tax code and agency regulations show that FedEx is not entitled to…