New Meta Tax Fight Debuts IRS Transfer Pricing ‘Double Tap’

Meta Platforms Inc. may have thought its transfer pricing problems with the IRS ended with a mixed decision from the US Tax Court last spring. Not so much.

Just months later, the agency took further action, and now the company could be the first to test new-found, controversial IRS assertiveness around periodic adjustments and transfer pricing.

The court’s May ruling closed the book on a long-running tax fight over whether Meta properly priced an intellectual property transfer to an Irish subsidiary in 2010, though both parties are still haggling over how to apply the result.

In September, Meta received a ...