The US Court of Appeals for the Second Circuit has held that global interest netting of section 6621(d) of the US Internal Revenue Code (IRC) may apply retrospectively even when the statute of limitation has expired for one leg of the period of overlapping indebtedness. Exxon Mobil Corp. & Affiliated Cos. v. Commissioner of Internal Revenue, Docket Nos. 11-2814 (Lead) 11-2817 (Con) (…