The Resource Eighth Circuit skeptical of Medtronic's CUT analysis, vacates tax court decision

Eighth Circuit skeptical of Medtronic's CUT analysis, vacates tax court decision

Label
Eighth Circuit skeptical of Medtronic's CUT analysis, vacates tax court decision
Title
Eighth Circuit skeptical of Medtronic's CUT analysis, vacates tax court decision
Creator
Subject
Language
eng
Summary
On 16 August 2018, in a 3-0 decision, the Eighth Circuit overturned the Tax Court's June 2016 decision in the dispute between the Internal Revenue Service (IRS) and Medtronic, Inc. concerning the transfer pricing treatment of an intercompany licensing arrangement and remanded the case for further consideration. This is a rare victory for the IRS in a transfer pricing case. Could it herald a reversal of the IRS's long string of losses? This article briefly describes the original Tax Court case and the Eighth Circuit opinion; discusses the importance of the opinion to transfer pricing law and practice; addresses how the proper resolution of the case would better reflect the functions, assets and risks of the parties; and suggests an alternative analysis that would address flaws in the analyses of both the Tax Court and the IRS
Citation source
In: Tax management transfer pricing report. - Arlington. - Vol. 27 (2018), no. 18 ; 4 p
http://library.link/vocab/creatorName
Chamberlain, D.G
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • case law
  • transfer pricing
  • intangibles
  • licensing
  • intercompany transaction
  • comparable uncontrolled transaction method
Label
Eighth Circuit skeptical of Medtronic's CUT analysis, vacates tax court decision
Instantiates
Publication
Label
Eighth Circuit skeptical of Medtronic's CUT analysis, vacates tax court decision
Publication

Library Locations

    • IBFD Library AmsterdamBorrow it
      Rietlandpark 301, Amsterdam, 1019 DW, NL
      52.3736660 4.9336932
Processing Feedback ...