On 29 February 2016, an opinion of the U.S. Tax Court was published concerning whether the IRS must determine separate taxable income of controlled entities for transfer pricing adjustment purposes and whether related transactions may be aggregated. The case involves Guidant Corp., the U.S. parent of a group engaged in the development, manufacture and sale of medical devices.
For the years concerned (2001-2007), Guidant group's U.S. subsidiaries conducted transactions with foreign affiliates…