A federal appeals court panel kept questions to a minimum Tuesday during oral arguments between
IRC Section 482 empowers the IRS to reallocate income from offshore subsidiaries back to a US parent corporation in order to accurately reflect the parent’s US taxable income. To do so, the government determines the arm’s-length price for intercompany transactions using the best-fitting transfer pricing method.
The IRS and Medtronic each appealed a Tax Court decision that adopted its own, “unspecified” compromise method for ...
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