2 Tax Decisions Hold Key Transfer Pricing Takeaways

By Richard Slowinski and Stefanie Kavanagh (October 13, 2022, 2:16 PM EDT) -- The judicial branch was busy over the summer churning out transfer pricing cases, with the U.S. Court of Appeals for the Sixth Circuit's decision in Eaton Corp. and Subsidiaries v. Commissioner, involving the IRS' ability to cancel an advance pricing agreement, or APA, and the U.S. Tax Court's decision in Medtronic Inc. v. Commissioner — Medtronic II — concerning whether the comparable uncontrolled transaction, or CUT, is the best method for testing the licensing agreements between Medtronic US and Medtronic Puerto Rico....

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