The Tax Court issued its second opinion in Medtronic following a remand by the US Court of Appeals for the Eighth Circuit (Medtronic, Inc. v. Comm’r, 900 F.3d 610 (8th Cir. 2018)) of its earlier decision. In that...more
8/25/2022
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IRS ,
License Agreements ,
Medtronic ,
Patent Litigation ,
Patents ,
Puerto Rico ,
Royalties ,
Siemens ,
Subsidiaries ,
Tax Court ,
Transfer Pricing
Medical device manufacturer, Medtronic, began its second trial on June 14 in the US Tax Court in a $1.36 billion transfer pricing dispute with the IRS. The trial concluded on June 25 and is among the most significant transfer...more
7/6/2021
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Business Profits ,
Foreign Profits ,
IRS ,
Medical Devices ,
Medtronic ,
Multinationals ,
Parent Corporation ,
Popular ,
Puerto Rico ,
Tax Court ,
Transfer Pricing