The Resource In appealing Medtronic, IRS continues to argue for aggregate approach over adjusted comparable uncontrolled transaction

In appealing Medtronic, IRS continues to argue for aggregate approach over adjusted comparable uncontrolled transaction

Label
In appealing Medtronic, IRS continues to argue for aggregate approach over adjusted comparable uncontrolled transaction
Title
In appealing Medtronic, IRS continues to argue for aggregate approach over adjusted comparable uncontrolled transaction
Creator
Subject
Language
eng
Summary
This article examines licensed manufacturer structures, prior case law involving the structures, the Tax Court's decision in Medtronic Inc. v. Commissioner, the Swiss supply agreement issue and the section 367(d) issue, and the potential significance of the decision if it is upheld on appeal
Citation source
In: Tax management transfer pricing report. - Arlington. - Vol. 26 (2017), no. 12 ; 4 p
http://library.link/vocab/creatorName
  • Hayri, A
  • Hawes, J
Geographic coverage
  • North America
  • Europe
Language note
English
http://library.link/vocab/subjectName
  • case law
  • comparable uncontrolled transaction method
  • licensing
  • manufacturing industry
Label
In appealing Medtronic, IRS continues to argue for aggregate approach over adjusted comparable uncontrolled transaction
Instantiates
Publication
Label
In appealing Medtronic, IRS continues to argue for aggregate approach over adjusted comparable uncontrolled transaction
Publication

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