Court Denies Medtronic Bid to Rethink Transfer Pricing Case (1)

A three-judge panel at the Eighth Circuit denied Medtronic Inc.'s request to reconsider a recent decision in its transfer pricing dispute with the IRS over how it allocated income to a subsidiary in Puerto Rico.

The US Court of Appeals for the Eighth Circuit had remanded the case to the US Tax Court in September, rejecting that court’s opinion applying a bespoke unspecified method to determine how Medtronic should have valued its transfer of intellectual property to a Puerto Rican subsidiary.

The ruling also rejected Medtronic’s preferred method to allocate the income.

The company last month requested that the ...