From Jesse Drucker, Alexandra Ostasiewicz, June Kim, and Joey Sendaydiego, the New York Times produced a video explaining dispute between Meta (the holding company of Facebook) and the IRS that is currently pending in the Tax Court. At issue is a notice of deficiency from the IRS of just under $16 billion (before interest and penalties) with respect to Meta Platforms’ 2017, 2018, and 2019 tax years. While the video focuses on the infamous “Double Irish” tax strategy, the central focus of the lawsuit is over the IRS’ application of section 482.

Part of what is at stake in Meta’s dispute is over the validity of Treas. Reg. § 1.482-7. Those regulations provide transfer pricing rules for certain cost sharing arrangements, and Meta is challenging the regulations as invalid on the basis that the regulations “contrary to sections 482 and 6501(a), does not reflect the best reading of section 482, exceeds Treasury’s rule making authority, was not the product of reasoned decision making, and was not issued in compliance with the requirements of the Administrative Procedure Act.”

For further detail about Meta’s dispute, Ryan Finley at Tax Analysts has a detailed, three-part seriespublished in Tax Notes International. (Click Part 1, Part 2, and Part 3 to read further.)