On 9 June 2016, the U.S. Tax Court filed its memorandum opinion concerning the IRS's income allocations under section 482 between Minnesota-based Medtronic Inc. (Medtronic US) and its Puerto Rican subsidiary for the 2005 and 2006 tax years. The allocations resulted in income tax deficiencies of USD 548 million and USD 810 million for Medtronic US for the two tax years respectively. The case involved three main issues: Whether income related to intercompany licenses for the intangible property required to manufacture certain medical devices should be reallocated under section 482 to Medtronic US from its Puerto Rican subsidiary, Medtronic Puerto...