UnitedHealth Faces IRS Tax Dispute Over Foreign Subsidiary Transactions

UnitedHealth Group is facing a tax dispute with the Internal Revenue Service (IRS) over foreign subsidiary transactions. The IRS has proposed adjustments that would increase the company's taxable income for each year from 2017 to 2020, and potentially subsequent years.

The case centers on transfer pricing, which determines how profits are allocated between jurisdictions and where taxes are paid. Under Section 482 of the US tax code, the IRS can adjust taxable income if it concludes that transactions between related entities were not priced appropriately.

UnitedHealth has not disclosed the foreign subsidiary involved or the specific transactions under review. The company's spokesperson stated that they disagree with the proposed adjustments and intend to contest them, saying their tax positions are properly supported.