Author : M.R. Martin
Publisher :
ISBN 13 :
Total Pages : pages
Book Rating : 4.:/5 (126 download)
Book Synopsis 'Medtronic V. Commissioner' : a Taxpayer Win on Transfer Pricing, Commensurate with Income, and Section 367 Issues by : M.R. Martin
Download or read book 'Medtronic V. Commissioner' : a Taxpayer Win on Transfer Pricing, Commensurate with Income, and Section 367 Issues written by M.R. Martin and published by . This book was released on 2016 with total page pages. Available in PDF, EPUB and Kindle. Book excerpt: 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.