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- Title
Back to the Future? Medtronic and the Future of Transfer Pricing.
- Authors
Avi-Yonah, Reuven S.
- Abstract
The article focuses on the decision of the U.S. Tax Court in the case related to medical device company Medtronic with the transfer pricing regulations with the changes in Section 482 of the U.S. Internal Revenue Code (IRC). Topics discussed include issue of proper transfer pricing under the arm's-length standard (ALS), Tax Court rejected the U.S. Internal Revenue Service (IRS) attempt to ignore the transfer of the intangibles and allocate the income and judicial interpretations of section 482.
- Subjects
UNITED States. Tax Court; MEDTRONIC PLC; TRANSFER pricing laws; UNITED States. Internal Revenue Code; ARM'S length transactions; UNITED States. Internal Revenue Service; LAW; ACTIONS &; defenses (Law)
- Publication
International Tax Journal, 2016, Vol 42, Issue 4, p33
- ISSN
0097-7314
- Publication type
Article