Microsoft—IRS issued Notice of Proposed Adjustment seeking $28.9 billion in additional tax from Microsoft over transfer-pricing arrangements
Microsoft disclosed in an October 11, 2023 SEC 8-K that the IRS had issued a Notice of Proposed Adjustment seeking approximately $28.9 billion in additional federal tax for fiscal years 2004-2013, related to Microsoft's transfer-pricing arrangements between US and Puerto Rico operations that had allocated billions in profits to lower-tax jurisdictions. Microsoft disputed the assessment and indicated it would appeal through IRS administrative processes; the case is among the largest-ever IRS transfer-pricing assessments against any company.
Scoring Impact
| Topic | Direction | Relevance | Contribution |
|---|---|---|---|
| Corporate Transparency | -against | secondary | -0.50 |
| Tax Practices | -against | primary | -1.00 |
| Overall incident score = | -0.885 | ||
Score = avg(topic contributions) × significance (critical ×2) × confidence (0.59)
Evidence (1 signal)
Microsoft disclosed IRS Notice of Proposed Adjustment seeking $28.9B in additional tax
Microsoft's October 11, 2023 SEC 8-K filing disclosed the IRS Notice of Proposed Adjustment seeking $28.9 billion in additional federal tax for fiscal years 2004-2013 related to transfer-pricing arrangements; among the largest IRS transfer-pricing assessments ever issued.