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Facebook Tax Bill Over Ireland Move Could Cost $5 Billion

  • IRS issues notice for 2010 tax year over operations transfer
  • Facebook plans to challenge notice in federal tax court

Facebook Inc.’s future cash flows and results could suffer a major blow if it loses a battle over new U.S. tax liabilities related to the transfer of its global operations to Ireland in 2010.

The Internal Revenue Service delivered a notice of deficiency to the social media giant Wednesday for $3 billion to $5 billion, plus interest and penalties, based on the agency’s audit of Facebook’s transfer pricing, the company said in a regulatory filing Thursday. Facebook, which plans to challenge the notice in federal tax court, said its balance sheet could suffer if it’s held liable.

Facebook said in the filing that the liability “could have a material adverse impact” on its finances, results or cash flows. “In addition, the determination of our worldwide provision for income taxes and other tax liabilities requires significant judgment by management, and there are many transactions where the ultimate tax determination is uncertain.”

The IRS on Monday asked a federal magistrate judge in California to force the company to turn over detailed internal corporate records related to the value of the assets moved to Ireland. They included all...


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