This is actually a simple argument:
Facebook could be liable to pay between $3 to $5bn in extra US tax after an extensive investigation by the US Internal Revenue Service (IRS) into the way the tech company transferred assets to Ireland.
The tax agency has been exploring whether Facebook deliberately deployed complex financial processes designed to minimize the amount of US tax it paid.
And it’s not that one either but then who expects The Guardian to get this stuff right?
Facebook transferred the international rights to exploit its IP offshore in 2010.
This is legal and not complex. The question is, what price?
For that IP must be transferred at market value. Uncle Sam gets tax on that transfer value, obviously.
So, what was the value of Facebook’s international IP in 2010? Opinions will differ, obviously. Private company although one with limited share transactions on Second Market. Total valuation that year anything between $10 billion and $50 billion. How much of that accrues to solely the foreign rights to the IP?
Piece of string?
But it would be fascinating to see that they’d got that valuation hugely wrong.