IRS’s Win in Long Tax Court Battle Also Has Upside for Facebook

May 23, 2025, 8:29 PM UTC

The US Tax Court’s long-anticipated ruling Thursday in Facebook’s big transfer-pricing battle with the IRS was a split decision—and not everyone agrees who came out ahead.

The court sided with the IRS on the method and regulations it used to determine the value of assets under a cost-sharing arrangement between Facebook parent company Meta Platforms Inc. and its Irish subsidiary. Some tax professionals said the decision will ease the IRS’s pursuit of future cases against other technology companies.

It’s a “huge win for the IRS,” said Andrew Silverman, a tax policy analyst at Bloomberg Intelligence. The precedent “is the main ...

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