Meta vs. IRS: $16 Billion Tax Battle Over Ireland Profits Tests ‘Periodic Adjustments’ Strategy
The IRS is seeking $15.89 billion in additional taxes from Meta for 2017–2019, targeting profits shifted to an Irish affiliate through a 2010 cost-sharing deal. On December 18, the agency escalated its case by invoking “periodic adjustments,” allowing it to use Meta’s actual post-deal results to challenge earlier transfer pricing. Meta disputes the IRS analysis and is contesting the claim in U.S. Tax Court.