US Appeals Court reverses Tax Court's CUP-acceptance in Medtronics, holds findings on comparability inadequate

Aug 21,2018

US Court of Appeals (Eighth Circuit) reverses Tax Court’s acceptance of Medtronic’s adoption of comparable uncontrolled transaction ("CUT") method (with certain adjustments) for benchmarking royalty received from Medtronic Puerto Rico (AE) for licenses to use certain intangibles for manufacture of highly regulated medical devices; Regarding Tax Court’s adoption of agreement between Medtronic and Pacesetter to cross-license their...


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