Facebook Will Challenge Tax Bill Of Up To $5 Billion Stemming From Ireland Asset Shift

Facebook was on the receiving end of a "statuary notice of deficiency" from the IRS, which Facebook detailed in a regulatory filing. The company said it received the notice from the IRS on July 27, 2016 relating to "transfer pricing with our foreign subsidiaries in conjunction with the examination of the 2010 tax year."

The company added that while the notice applies to just its operations in 2010, the IRS could apply its position for tax years subsequent to 2010, which could result in a federal tax liability of $3 billion to $5 billion — plus any relevant interest and penalties.

The company cautioned that the additional tax "could have a material adverse impact" on its financial position, results of operations or cash flows. However, the company intends to dispute the charges.

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"We do not agree with the position of the IRS and will file a petition in the United States Tax Court challenging the Notice," Facebook said in its filing.

According to Fortune, U.S. regulators do not agree with the method that Facebook's accounting firm, Ernst & Young, used to evaluate assets that Facebook shifted to its Ireland-based subsidiary.

Fortune noted that Facebook may have shifted intellectual property and parked profits outside of the United States to avoid the nominal 35 percent corporate tax rate.

"Facebook complies with all applicable rules and regulations in the countries where we operate," a Facebook spokesperson also told Fortune.

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