Medtronic, IRS Agree On $14M Tax Bill In Transfer Pricing Row

Law360, Washington (January 23, 2017, 8:23 PM EST) -- The IRS has agreed to slash the calculation of Medtronic Inc.’s tax deficiencies to roughly $14 million in a transfer pricing dispute involving intellectual property royalties from its Puerto Rican manufacturing operations from 2005 to 2006, heeding a U.S. Tax Court decision rejecting the agency’s decision to increase Medtronic's taxable income by $1.36 billion.

A tax computation agreement between the parties filed earlier this month, which is subject to court approval, includes $26.4 million in unpaid deficiencies for the tax year ended April 2005 and a $12.5 million tax overpayment for the year ended April 2006. In order to calculate Medtronic's income,...

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