Abstract
In this report, the authors explain how the Tax Court's recent decision in the Facebook transfer pricing case - although widely viewed as a victory for the taxpayer, Meta Platforms Inc.- could instead be a Pyrrhic victory because it enables the IRS to pursue a potentially substantial periodic adjustment against the company. The views expressed in this report are solely the authors' and do not necessarily reflect those of any other person or institution.
Disciplines
Law and Economics | Tax Law
Date of this Version
9-17-2025
Working Paper Citation
Curtis, Stephen L.; Avi-Yonah, Reuven S.; and Chamberlain, David G., "Facebook Decision Enables IRS to Seek - CWI Enforcement Against Meta" (2025). Law & Economics Working Papers. 311.
https://repository.law.umich.edu/law_econ_current/311