Agreed, of course there isn't a "right" way. But companies should be internally consistent in how they do these things. So, I can imagine if you (as the IRS)

Agreed, of course there isn't a "right" way. But companies should be internally consistent in how they do these things. So, I can imagine if you (as the IRS) can demonstrate that they used on method of doing this sort of thing for some stakeholders, but another for the sale to Irish subsidiary with no real justification ... you might just have an argument this was for tax avoidance purposes. Also I didn't mean to suggest that absolute value comparison was the right way to do this. Just that it is entirely plausible the FB intentionally lowballed the sale. It's clearly the reason these companies are in Ireland at all. Cases like this I suppose are about defining the line between "fair play" and not.