New Meta Challenge to IRS Adjustment: Transfer Pricing Report

Hello and welcome to the Transfer Pricing Report. I’m Caleb Harshberger, and this week we’re checking out the new tax fight between Meta and the IRS—with potentially big implications for transfer pricing.

Well, I guess we knew a case like this was coming.

Just months after a May Tax Court decision on a transfer pricing dispute with the IRS, Meta received new adjustments from the agency, this one for $16 billion in unpaid taxes and related penalties for 2017-19.

Now the company could be the first to test the agency’s newfound—and controversial—assertiveness around periodic adjustments and transfer pricing.

Meta sued ...