Microsoft received Notices of Proposed Adjustment from the Internal Revenue Service for an additional tax payment of $28.9 billion, the company said in an 8-K filing Wednesday.
Microsoft said the dispute concerns the company's allocated profits between countries and jurisdictions between 2004 and 2013. It said up to $10 billion in taxes that the company has already paid are not reflected in the proposed adjustments made by the IRS.
Microsoft plans to contest the notices through the IRS' administrative appeal and is willing to go to judicial proceedings, if necessary.
"Microsoft disagrees with these proposed adjustments and will pursue an appeal within the IRS, a process expected to take several years," the company said in its filing. "We believe we have always followed the IRS's rules and paid the taxes we owe in the U.S. and around the world."
Microsoft said that as of Sept. 30, 2023, it believes its allowances for income tax contingencies are adequate.
Rhouliha on October 11st, 2023 at 21:21 UTC »
TLDR: The IRS has issued a $28.9B notice of proposed adjustments ("NOPA") related to its allocation of profits between countries (i.e., it's transfer pricing). Presumably, the had income in lower tax jurisdictions that the IRS thinks should have been U.S. source income.
Microsoft is appealing through the IRS' administrative appeal process and is willing to go to judicial proceedings, if necessary.
This could take a long time to resolve.
buttergun on October 11st, 2023 at 21:17 UTC »
"A billion here, a billion there, and pretty soon you're talking real money."
Audioengineer68 on October 11st, 2023 at 21:13 UTC »
Looks like those IRS agents paid for themselves.