Tax Coda

Tax Coda

Facebook reignites transfer pricing battle with the IRS

If the IRS prevails here, periodic adjustments shift from a theory to a standing enforcement tool.

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Tax Coda
Dec 19, 2025
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Facebook (a.k.a. Meta) is back in Tax Court over the same IP transfer it thought had been resolved.

The IRS issued new adjustments in September tied to later cost-sharing years, not the original 2010 transfer.

Facebook says the agency is relitigating issues that have already been decided. The case now puts the IRS’s aggressive view of periodic, commensu…

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