Medtronic 2015 Annual Report Download - page 44

In addition, in the IRS Notice, the U.S. Treasury Department and the IRS announced their intention to issue additional guidance
in the future intended to restrict our ability to undertake certain transactions which could reduce our U.S. tax liability. According
to the IRS Notice, such guidance may include, among other things, limitations on our ability to deduct interest on certain
intercompany debt for U.S federal income tax purposes. We are unable to predict the likelihood that any such guidance will be
issued, the nature of regulations that may be promulgated thereunder or the effect such guidance may have on our business.
The Transaction may not allow us to maintain competitive global cash management and a low effective corporate tax rate.
While we believe that being incorporated in Ireland should help us maintain a competitive worldwide effective corporate tax
rate and provide flexible global cash management, we cannot give any assurance as to what our effective tax rate will be,
however, because of, among other things, uncertainty regarding the tax policies of the jurisdictions where we will operate.
Additionally, the tax laws of Ireland and other jurisdictions could change in the future, and such changes could cause a material
change in our effective tax rate.
Legislative or other governmental action relating to the denial of U.S. federal or state governmental contracts to U.S.
companies that redomicile abroad could adversely affect our business.
Various U.S. federal and state legislative proposals that would deny governmental contracts to U.S. companies that move their
corporate location abroad may affect us. We are unable to predict the likelihood that, or final form in which, any such proposed
legislation might become law, the nature of the regulations that may be promulgated under any future legislative enactments, or
the effect such enactments and increased regulatory scrutiny may have on our business.
Item 1B. Unresolved Staff Comments
None.
Item 2. Properties
Our principal executive office is located in Ireland and leased by us. Our main operational offices are owned by us and located
in the Minneapolis, Minnesota metropolitan area. Manufacturing or research facilities are located in Ireland, the U.S. (in sixteen
states), Puerto Rico, Brazil, Canada, Costa Rica, Denmark, Dominican Republic, France, Germany, India, Israel, Italy, Japan,
Malaysia, Mexico, The Netherlands, The People’s Republic of China, Singapore, South Korea, Switzerland, Thailand, Turkey,
United Kingdom, and Vietnam. Our total manufacturing and research space is approximately 12.8 million square feet, of which
approximately 60 percent are located within the U.S. Approximately 50 percent of the manufacturing or research facilities are
owned by us and the balance is leased.
We also maintain sales and administrative offices in the U.S. at 70 locations in 28 states or jurisdictions and outside the U.S. at
275 locations in 67 countries. Most of these locations are leased. We are using substantially all of our currently available
productive space to develop, manufacture, and market our products. Our facilities are in good operating condition, suitable for
their respective uses, and adequate for current needs. We currently are evaluating our properties for additional cost savings and
efficiencies, due to the acquisition of Covidien during fiscal year 2015, and our ongoing cost savings initiatives.
Item 3. Legal Proceedings
A discussion of the Company’s legal proceedings is contained in Note 16 to the consolidated financial statements in “Item 8.
Financial Statements and Supplementary Data” in this Annual Report on Form 10-K.
Item 4. Mine Safety Disclosures
Not applicable.
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