My wife is a CPA and former auditor at E&Y, and mentions that transfer pricing is one of the trickiest things in corporate accounting (relying on "judgment call

My wife is a CPA and former auditor at E&Y, and mentions that transfer pricing is one of the trickiest things in corporate accounting (relying on "judgment calls" rather than binary decisions). It comes as no surprise that the IRS and Facebook are having a tussle over transfer pricing. Many companies have the same beef with the IRS (not just tech companies) including her employer LVMH based in Paris. It'll just be a matter of negotiation and litigation.