According to the latest United Health documentation, the company is in dispute with the United States Internal Revenue Service (IRS) over a tax adjustment proposal. The company disclosed that the dispute related to the pricing of its transactions with an overseas subsidiary between 2017 and 2020, and that the tax authorities intended to significantly increase taxable revenue in those years, a judgement that the company would not accept.
Transactions involving 2017 to 2020
According to company quarterly documents in May and August, these notices cover the tax years 2017 to 2020. IRS argues that the relevant transaction pricing may result in the United Health underestimation of United States taxable income and does not preclude the extension of similar adjustments to subsequent years.
In its latest paper, however, the company indicated that its tax treatment was “well-founded” and that it planned a “strong defence” against the proposed adjustment. The current disclosure does not indicate the name, place of incorporation or the specific type of transaction of the overseas subsidiaries involved.
Amounts and transaction details remain undisclosed
This means that the outside world is temporarily unable to judge the extent of the dispute. The company document does not attach the amount of taxes to be collected by IRS, nor does it disclose whether the dispute is concentrated in intellectual property rights, fees for services, cost-sharing or other cross-border internal transactions.
Transfer pricing usually refers to the setting of prices by TNCs for transactions between related entities in different countries. Since these prices affect the distribution of profits between jurisdictions, they also directly affect the place of taxation and the level of tax liability.
The United States tax authorities have continuously strengthened their review of such arrangements for more than a decade, focusing on whether United States multinationals transfer profits through their overseas subsidiaries. A similar controversy had previously occurred in large enterprises such as Coca-Cola, Meta and Medtronic.
Similar cases often last for years.
Such cases usually take a long time and may be very large. Public cases show that the dispute between Coca-Cola and IRS may eventually involve some $20 billion in taxes and interest; Meta is also defending a notice involving $15.89 billion in additional taxes.
The United Health does not currently give a potential risk exposure to the case. The company documents show that its total unrecognized tax interest at the end of 2025 rose to $5.6 billion, up from $4.1 billion a year earlier, but the company made it clear that this figure should not be directly understood as the corresponding amount for the current dispute.
Follow-up or access to appeals and proceedings
Under United States tax procedures, the notice of proposed adjustment is not a final decision, nor is it equivalent to a formal fine or a final tax decision. If the parties are unable to resolve their differences at the review stage, the company may have access to IRS administrative appeal procedures and may then have further recourse to the courts.
United Health stated that, based on the information currently available, the company ' s provision for uncertain tax matters remained adequate and would continue to contest the adjustment proposal.
Additional information:Fortune reported that the United States Internal Revenue Service did not comment on this. Under United States federal law, tax authorities are usually not permitted to discuss in public the specifics of individual taxpayers.