alt Hacker News> [The IRS] say the company failed to report roughly $54 billion in income and owes nearly $16 billion in back taxes and penalties.
That's... just not very much? The claim is that Meta's global ex-US income for the last 15+ years is less than a single year's US income? I really wonder how they came up with this number.
Disappointingly little detail in the article about how the IRS justifies the claim that the 2010 price was low (obviously, later profits would not be completely foreseeable at the time -- in 2010 Facebook was simply a much smaller business), or any detail about the 1986 law. It seems pretty farcical to retcon a purchase for being too cheap with evidence from 16 years later.
the B is specifically the delta on the IP transfer pricing -- the IRS is saying the 2010 valuation of the intangibles moved to Ireland was too low, and then projecting forward what the income should have been attributed to the US entity under arm's-length pricing. it's not Meta's total ex-US income, it's the gap between what was reported and what IRS thinks a proper cost-sharing arrangement would have produced. the hard part for IRS is always that the 2010 valuation is inherently speculative -- Facebook was pre-IPO and the IP value is defined by future performance you can't know at transfer.