IRS seeks $28.9B additional tax from Microsoft for 2004-2013 transfer pricing

MICROSOFT CORP

IRS issued Notices of Proposed Adjustment (NOPAs) on Sept 26, 2023, seeking $28.9B plus penalties and interest.
Microsoft says it has paid over $67B in U.S. taxes since 2004 and will vigorously contest the NOPAs.
Potential reduction of up to $10B from taxes paid under the Tax Cuts and Jobs Act not reflected in the NOPAs.
Company expects no final resolution within 12 months; believes current tax contingency allowances are adequate.
Dispute centers on intercompany transfer pricing and cost-sharing arrangements for intellectual property.

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