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) (8 August 2012). Under IRC section 6621, interest owned by a corporate taxpayer to the IRS on tax underpayments is calculated at a higher percentage rate than interest owed to a corporate taxpayer by the IRS on tax overpayments....