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Arbitrary and Capricious IP License

McDermott Will & Emery

Arm’s Length Royalty Rates Save Medtronic from $1.36 Billion Tax Deficiency

McDermott Will & Emery on

Addressing whether certain intercompany technology license agreements were negotiated at arm’s length, the US Tax Court rejected the Internal Revenue Service’s (IRS’s) alleged $1.36 billion tax deficiency and determined that...more

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