36 min

Breaking Down Facebook’s Litigation in the Tax Court, Part 2 | tax break Episode 16 tax break

    • Business News

Facebook is embroiled in a transfer pricing dispute with the IRS in Tax Court. This week on tax break, Steve and Loren conclude their discussion of what's at issue in the case. Listen to part 1 of the discussion in Episode 14.


Topics discussed:


Basics of the dispute

Whether aggregation of the three disputed royalties is reliable here

Pricing the Platform Contribution Transaction royalty

Challenge to validity of the -7T regulations

Nature of the User Base and associated royalty

Subsequent legal changes and changes to structure


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Questions? Contact us at podcasts@milchev.com.


tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.


tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you’ll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.

Facebook is embroiled in a transfer pricing dispute with the IRS in Tax Court. This week on tax break, Steve and Loren conclude their discussion of what's at issue in the case. Listen to part 1 of the discussion in Episode 14.


Topics discussed:


Basics of the dispute

Whether aggregation of the three disputed royalties is reliable here

Pricing the Platform Contribution Transaction royalty

Challenge to validity of the -7T regulations

Nature of the User Base and associated royalty

Subsequent legal changes and changes to structure


*********


Questions? Contact us at podcasts@milchev.com.


tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.


tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you’ll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.

36 min