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…