The Resource 'Medtronic v. Commissioner' : a taxpayer win on transfer pricing, commensurate with income, and Section 367 Issues

'Medtronic v. Commissioner' : a taxpayer win on transfer pricing, commensurate with income, and Section 367 Issues

Label
'Medtronic v. Commissioner' : a taxpayer win on transfer pricing, commensurate with income, and Section 367 Issues
Title
'Medtronic v. Commissioner' : a taxpayer win on transfer pricing, commensurate with income, and Section 367 Issues
Creator
Subject
Language
eng
Summary
Commentary on the opinion of 9 June 2016, released by the U.S. Tax Court in Medtronic, Inc. and Consolidated Subsidiaries v. Commissioner case. The Internal Revenue Service had taken issue with the transfer pricing of transactions between Medtronic, Inc. and its Puerto Rican manufacturing arm under Section 482 of the Internal Revenue Code. Finding the IRS's application of the comparable profits method (CPM) to the transactions arbitrary and capricious, and taking issue as well with the taxpayer's comparable uncontrolled transaction (CUT) methodology, the court ultimately made its own decision as to arm's-length pricing, arriving at new allocations by making adjustments to the taxpayer's original CUT approach
Citation source
In: Tax management international journal. - Arlington. - Vol. 45 (2016), no. 11 ; 16 p
http://library.link/vocab/creatorName
  • Martin, M.R
  • Horowitz, M
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • transfer pricing
  • case law
  • arm's length principle
Label
'Medtronic v. Commissioner' : a taxpayer win on transfer pricing, commensurate with income, and Section 367 Issues
Instantiates
Publication
Label
'Medtronic v. Commissioner' : a taxpayer win on transfer pricing, commensurate with income, and Section 367 Issues
Publication

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