Medtronic Ruling Slams Tax Court Method: Transfer Pricing Report

Sept. 5, 2025, 9:04 AM UTC

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week the IRS notched another win (basically) with a ruling on its long-running dispute with Medtronic—sending the 15-year case back to the Tax Court for reconsideration.

After two decades from the tax years in question, what’s a little more time hashing things out in the courts?

The Eighth Circuit sent the Medtronic case back to the Tax Court Wednesday—but not before squashing the Tax Court’s controversial choice to side with neither party but to apply its own unspecified method to calculate if Medtronic’s intellectual property deal with ...

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