Medtronic, Inc. v. Comm'r of Internal Revenue

WOLLMAN, Circuit Judge.

The Commissioner of Internal Revenue (Commissioner) appeals from the tax court's valuation of Medtronic, Inc. and its consolidated subsidiaries' (Medtronic) true income for the 2005 and 2006 tax years.

The Commissioner characterizes this dispute as involving "the classic case of a U.S. multinational taxpayer (Medtronic) shifting income from its highly profitable U.S. operations and intangibles to an offshore subsidiary operating in a tax haven (Medtronic [Puerto Rico] ), by charging an artificially low rate for the intangibles." Appellant's Reply Br. 1. Medtronic's view…