Medtronic Seeks Panel Rehearing of Transfer Pricing Decision

Medtronic Inc. is asking a three-judge panel of the Eighth Circuit to rethink a recent transfer pricing decision siding with the IRS on how to value its transfer of intellectual property to a Puerto Rican subsidiary.

On the heels of a decision in favor of 3M Co. in a separate transfer pricing dispute, the medical device manufacturer said Monday that the US Court of Appeals for the Eighth Circuit’s September opinion “misapprehended the transfer pricing regulations.”

The IRS can reallocate income from offshore subsidiaries back to a US parent company in order to accurately reflect the parent’s US taxable income ...