On 27 July 2016, Facebook received a statutory notice of deficiency from the IRS relating to its 2010 tax year. In examining Facebook's transfer pricing for the year, the IRS found issues with Facebook's transfer of intangibles to its Ireland subsidiary, which included property rights relating to its online platform, online marketing intangibles and online communities. According to the IRS, the intangibles had been undervalued by billions of dollars by valuing closely related intangibles on a stand-alone basis rather than in the aggregate. As a result, Facebook faces a potential tax liability of USD 3 to 5 billion. In response,...