Facebook, IRS Remain at Loggerheads in Transfer Pricing Dispute

Facebook Inc. and the IRS both are asking the US Tax Court to weigh in again on how the social media giant’s payments to an Irish subsidiary should be valued for tax purposes, further extending the 15-year-old transfer pricing case.

The two parties filed briefs with the court Aug. 22 after they were unable to agree on how to assess the value of intangible assets Facebook assigned to its subsidiary. Facebook’s calculation calls for the transaction to be valued at about $7.79 billion, while the IRS’s model puts the value at around $8.24 billion.

They asked Judge Cary Douglas Pugh ...