Medtronic, IRS ‘Exploring’ End to Lengthy Transfer Pricing Feud

Medical device manufacturer Medtronic Inc. and the IRS have started settlement discussions to avoid further litigation in their long-running transfer pricing dispute, the parties told the US Tax Court.

The case, which has gone up to the US Court of Appeals for the Eighth Circuit twice in the more than 10 years that it’s been pending, centers around an intellectual property deal between Medtronic and its Puerto Rican subsidiary. The company and the IRS have been at odds over the method for determining the cost of the transaction and how to reallocate income from offshore subsidiaries to a US parent ...