$1.4 Billion Medtronic Dispute Tests Taxation of Multinationals

A major tax dispute involving medical device manufacturer Medtronic heads to trial Monday at the U.S. Tax Court, presenting a test of the methods used to tax multinational companies that shift assets overseas.

The case centers on Medtronic’s allocation of profits for tax purposes between its U.S. parent company, U.S. distributor, and Puerto Rican device manufacturer. While the IRS argued that the company owed nearly $1.4 billion in taxes, the U.S. Tax Court found in a 2016 opinion that it had underpaid by just about $14 million. In 2018, though, the U.S. Court of Appeals for the Eighth ...