Medtronic, Inc. v. Commissioner (I)

BVLaw
Full Text of Court Cases
June 9, 2016
3841 Surgical and Medical Instruments and Apparatus
339112 Surgical and Medical Instrument Manufacturing
federal taxation
licensing, royalty rate, transfer pricing, expert testimony, intangible assets, deficiency, lump sum license, comparable uncontrolled transaction, comparable profits method (CPM)

Medtronic, Inc. v. Commissioner (I)
Tax Ct. Memo LEXIS 111
US
Federal Court
Federal
United States Tax Court
Louis P. Berneman, Robert S. Pindyck (petitioner/taxpayer); A. Michael Heimert (respondent/IRS)
Kerrigan

Summary

In transfer pricing case centering on taxpayer’s intercompany licensing agreements, Tax Court finds CUT method is the best way to calculate arm’s-length royalty rates; court accepts taxpayer-proposed uncontrolled comparable but makes adjustments to account for differences in transactions.
Medtronic v. Comm'r, T.C. Memo
PDF, Size: 466 KB

See Also

In Transfer Pricing Case, Tax Court Fails to Perform Adequate CUT Analysis

In transfer pricing case centering on taxpayer’s intercompany licensing agreements, Tax Court finds CUT method is the best way to calculate arm’s-length royalty rates; court accepts taxpayer-proposed uncontrolled comparable but makes adjustments to account for differences in transactions.