It's interesting to see the court finally weigh in on the 2009 regulations. The fact that the valuation dropped from $19.9B to $7.8B just by adjusting the inputs shows how much power the IRS can wield—and how important it is for companies to have bulletproof documentation for their discount rates and revenue projections from day one.
The 'Double Tap' is real. Even after this ruling, the IRS is already coming back for the 2017–2019 years with another $16 billion deficiency notice. This case proves that in transfer pricing, the litigation never really ends—it just moves to the next tax cycle.
The IRS is like the terminator—it just won't stop. Meta thought they had a settlement path after the May ruling, but a $16B 'periodic adjustment' claim proves the agency is willing to re-litigate the same IP until they get the number they want. This is going to be the tax trial of the decade (again).
Don't pop the champagne at Meta HQ just yet. While the Tax Court slashed the 2010 deficiency, the IRS is already 'double tapping' with a new $16 billion claim for the 2017–2019 years. This isn't a conclusion; it's just the end of the first episode in a very expensive multi-season box set of IRS v. Big Tech.
It's interesting to see the court finally weigh in on the 2009 regulations. The fact that the valuation dropped from $19.9B to $7.8B just by adjusting the inputs shows how much power the IRS can wield—and how important it is for companies to have bulletproof documentation for their discount rates and revenue projections from day one.
The 'Double Tap' is real. Even after this ruling, the IRS is already coming back for the 2017–2019 years with another $16 billion deficiency notice. This case proves that in transfer pricing, the litigation never really ends—it just moves to the next tax cycle.
The IRS is like the terminator—it just won't stop. Meta thought they had a settlement path after the May ruling, but a $16B 'periodic adjustment' claim proves the agency is willing to re-litigate the same IP until they get the number they want. This is going to be the tax trial of the decade (again).
Don't pop the champagne at Meta HQ just yet. While the Tax Court slashed the 2010 deficiency, the IRS is already 'double tapping' with a new $16 billion claim for the 2017–2019 years. This isn't a conclusion; it's just the end of the first episode in a very expensive multi-season box set of IRS v. Big Tech.