According to recent reports, the U.S. IRS has filed a formal notice of appeal regarding the June 2016 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-2016-06-14/A/6- previous coverage}), which was seen as a major defeat for the IRS. The allocations had resulted in income tax deficiencies of USD 548 million and USD 810 million for Medtronic US for the tax years 2005 and 2006. The case concerned the allocation of intercompany licenses, whether royalty payments were at arm's length, and whether...