‘Medtronic’ Ruling Bolsters Multinational Corporate Tax Options

A US Tax Court ruling that resembled a Dr. Frankenstein creation in a $1.4 billion fight over medical device manufacturer Medtronic’s taxes pushed the door open wider for using unspecified methods to calculate multinational tax bills.

An “unspecified method” is one of four eligible methods under IRS regulations for determining the tax bills that arise when intangible property is transferred across borders between entities that are part of the same multinational company.

Judge Kathleen Kerrigan’s Aug. 18 opinion stitched together different methods and adjustments to create what could be a “new creature that’s walking the earth of ...