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‘Medtronic’ Decision Sent Back to Tax Court (1)

Aug. 16, 2018, 6:22 PM

Medtronic Inc. lost a skirmish with the IRS over the tax agency’s $2.2 billion intercompany pricing adjustment when a federal appeals court sent a trial court decision back for further analysis.

U.S. Court of Appeals for the Eighth Circuit Aug. 16 found that the U.S. Tax Court, in its June 2016 decision, had not adequately explained the way it valued the price of intercompany licenses transferred between the Minneapolis-based company and its offshore unit.

“The tax court did not address in sufficient detail whether the circumstances of the settlement between Pacesetter and Medtronic US were comparable to the licensing agreement ...

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