Litigation over how to assign royalties for intellectual property with an offshore subsidiary doesn’t consume the kind of billable attorney hours that patent disputes do, but the question can affect a multinational corporation’s bottom line in significant ways. The U.S. Tax Court recently decided on a method for assigning royalties to a Medtronic plc subsidiary located in Puerto Rico that fell between the rate sought by Medtronic and the rate sought by an appeals court, but that ultimate rate was close to that preferred by Medtronic, handing the company a better outcome than it might have predicted when the IRS filed suit.