Medtronic, Inc, etc. v. CIR

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Appellate - 8th Circuit

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  1. June 06, 2024

    Medtronic Urges 8th Circ. To Back Its Transfer Pricing Method

    Medical device maker Medtronic reiterated Thursday its bid for the Eighth Circuit to revive its method for pricing intangible property that was licensed to a Puerto Rican affiliate, arguing the government's concessions show why the company's approach is more reliable.

  2. April 15, 2024

    8th Circ. Urged To Revive IRS' Pricing For Medtronic

    The U.S. government urged the Eighth Circuit on Monday to side with the IRS' method for pricing the intangible property that medical device maker Medtronic licensed to a Puerto Rican affiliate, arguing it's the only way to determine arm's-length royalty rates.

  3. February 16, 2024

    Medtronic Urges 8th Circ. To Undo Transfer Pricing Ruling

    Medical device company Medtronic asked the Eighth Circuit on Friday to overturn a decision rejecting its pricing method for licensing intellectual property to its Puerto Rican affiliate, saying in the long-running case that Medtronic hadn't used the intercompany arrangement to underreport its income.

  4. January 01, 2024

    International Tax Cases To Watch In 2024

    The U.S. Supreme Court’s upcoming decision on a constitutional challenge to a repatriation provision could reverberate beyond the tax code’s measures for deferred foreign income, while Coca-Cola may make its own constitutional arguments in a long-running $3.3 billion transfer pricing dispute. Here, Law360 looks at key international tax cases to follow during 2024.

  5. December 15, 2023

    Tax Court's Medtronic Method Violates Regs, US Tells 8th Circ.

    The U.S. asked the Eighth Circuit on Friday to reject a transfer pricing method used by the U.S. Tax Court in a decision finding medical device company Medtronic Inc. underreported its income, saying the methodology violated Treasury regulations and still failed to accurately account for the company's income.