Tough Medicine, Part 2: Litigation lessons from Medtronic
JD Supra Law
AUGUST 25, 2022
2018)) of its earlier decision. In that earlier opinion (Medtronic I), the Tax Court held that Medtronic appropriately applied a comparable uncontrolled transaction (CUT) method to determine the arm’s-length royalty rate for certain licensing of intangible property, using a 1992 patent litigation settlement agreement.
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