On May 5, 2020, the Tax Court issued its opinion in Whirlpool Financial Corporation v. Commissioner (154 T.C. No. 9). The issue presented in Whirlpool Financial Corporation v. Commissioner was whether the income earned by the petitioner’s Luxembourg controlled foreign corporation (CFC) from sales of appliances to the petitioner and the petitioner’s Mexican CFC constituted foreign base company sales income (FBCSI) under IRC § 954(d) and, as such, was taxable to the petitioner as subpart F