On August 16, 2018, the U.S. Court of Appeals for the Eighth Circuit filed its decision on the appeal of the Commissioner of Internal Revenue regarding the U.S. Tax Court decision that the IRS had made arbitrary, capricious, or unreasonable allocations under Section 482 between Minnesota-based Medtronic Inc. and its Puerto Rican subsidiary ({News-2017-05-01/A/3-previous coverage}). The main point of the appeal was the Commissioner's view that the Tax Court had erred in not applying the correct transfer pricing method when calculating the arm’s length royalty rates for Medtronic’s intercompany licenses. In its decision, the Tax Court had held that Medtronic's...