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Chronicles

The story behind the story

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Inside the IRS's 8-year audit into Microsoft after the company sold its IP to a factory it owns in Puerto Rico to reduce tax rate on US profits from ~35% to ~2%

For years, the company has moved billions in profits to Puerto Rico to avoid taxes.  When the IRS pushed it to pay, Microsoft protested that the agency wasn't being nice.

ProPublica Paul Kiel

Context & Ripple Effects

This ProPublica investigation lands mid-arc in a decade-long fight between Microsoft and the IRS. The audit traces back at least to 2014, when the agency demanded testimony from Ballmer and other Microsoft leaders, and centers on the company's sale of intellectual property to a factory it owns in Puerto Rico — a structure that cut the tax rate on its US profits from roughly 35% to about 2%. The day after this piece ran, ProPublica published a parallel IRS probe into Facebook, including 2008 emails between Sandberg and Facebook's head of tax discussing havens for parking profits.

First-order effects

  • Microsoft faces an IRS demand to pay back taxes on billions in profits shifted to Puerto Rico, and has responded by protesting the assessment itself — disputing the agency's conduct rather than conceding the liability.
  • The 8-year audit puts Microsoft's transfer-pricing structure under direct examination, with executives personally drawn in through testimony demands.

Second-order effects

  • The IRS running near-simultaneous probes into Microsoft and Facebook signals the agency treating IP-sales-to-owned-factories as a repeatable playbook worth auditing across Big Tech, raising exposure for any company using the same structure.
  • A prolonged dispute over the Puerto Rico arrangement keeps billions in potential tax revenue contested, pressuring both sides toward a settlement or a precedent-setting court fight.

Third-order effects

  • The pattern holds past enforcement: by FY 2025 Microsoft's Ireland hub booked $47B in pretax profits, 38.1% of its global total — profit shifting migrating jurisdictions rather than stopping, now under EU country-by-country reporting rules that make such hubs visible.
  • If audits like this one keep stretching over years while companies appeal, the effective cost of aggressive tax structuring becomes a negotiated discount on the original bill — an outcome that shapes how multinationals price future structures.

The trend: US tech multinationals are shifting IP-driven profits across successive low-tax jurisdictions — Puerto Rico, then Ireland — faster than multi-year IRS audits can close the gap.

Discussion

  • @greene_dm Dan Greene on x
    Corporate tax avoidance is one of those things I understand in the abstract—of course they all play the shell game—but I didn't really get it until this play-by-play of Microsoft stealing tens of billions of dollars from the public coffers https://www.propublica.org/...
  • @bdsams Brad Sams on x
    An excellent report by @paulkiel about how Microsoft dodged taxes and changed the laws to win - technically they made it legal, but it's absolutely immoral - https://www.propublica.org/...
  • @eisingerj Jesse Eisinger on x
    It's the biggest audit in IRS history. Of what has been the largest company in the world. It's taken over a decade. And it's still not done. And it's not going well for the gutted IRS. @paulkiel's amazing story: https://www.propublica.org/...
  • @tekburger TekBurger&trade on x
    Shameful that @Microsoft hid $39B to avoid taxes with the help of crooks at KPMG. Then as the IRS got tough to claim tax back, Microsoft fought harder to hide it. Pay your goddamn taxes Microsoft. https://www.propublica.org/... https://twitter.com/...
  • @dpchiesa DinoChiesa on x
    I'm strongly in favor of American companies building great businesses. But when @Microsoft shelters all their North American profits in a tiny Puerto Rican company, to avoid paying US taxes, it's really shady & unbecoming. Pay your fair share, Microsoft. https://www.propublica.or…
  • @onpubcom Corey Taylor on x
    “In 2016 alone, according to an estimate by economists including Gabriel Zucman of the University of California, Berkeley, U.S. corporations avoided $61 billion in taxes by sending profits to tax havens.” https://www.propublica.org/...
  • @gardmaf Matthew Gardner on x
    Propublica's @paulkiel, reminding us once again that journalism is a noble, and vital, profession. Kiel tells the story of how an underfunded IRS team tried (& is still trying) to prove that Microsoft illegally shifted billions of $ into Puerto Rico. https://www.propublica.org/..…
  • @propublica @propublica on x
    Why did Microsoft sell its most valuable possession — its intellectual property — to an 85-person factory it owned in Puerto Rico? It is... not a mystery. But it lead to the biggest audit by dollar amount in the history of the IRS. https://www.propublica.org/...
  • @jeffreyfarrow Jeffrey L. Farrow on x
    Microsoft used Puerto Rico to avoid tax on $39 billion (for almost no jobs or investment). https://www.propublica.org/... The cost to Puerto Rico? $9 B/yr. in Federal funds, votes in the government that makes its national laws - and its local laws when it so desires, and bankrupt…
  • @drshaffopolis Chris Shaffer on x
    Maybe if the smartest people at Microsoft weren't busy figuring out how to dodge taxes they could figure out how to copy my hard drive down the hall and re-point a DNS record. https://www.propublica.org/...
  • @medievalworldus @medievalworldus on x
    Sounds a lot like Trump's tax schemes. Microsoft had told investors its revenues would grow 10% to 12% but told the IRS the figure was 4%. In another, the IRS found Microsoft had understated revenues by $15 billion. https://www.propublica.org/...
  • @drogon_dracarys Drogon on x
    For years, Microsoft has moved billions in profits to Puerto Rico to avoid taxes. When the IRS pushed it to pay, Microsoft protested that the agency wasn't being nice. Then it aggressively fought back in court, lobbied Congress and changed the law. https://www.propublica.org/...
  • @biancajoanie @biancajoanie on x
    This story about how giant U.S. corporations negotiated near to 0% tax rates with the Puerto Rico government is explosive. https://www.propublica.org/...
  • @lhfang Lee Fang on x
    Microsoft and Google, now valued at around a trillion dollars each, dodge paying taxes by manufacturing a fake sale of their intellectual property to subsidiaries in tax havens to declare their profits abroad https://www.propublica.org/...
  • @danpriceseattle Dan Price on x
    What's the danger in mega-companies becoming so big? Some are now more powerful than the U.S. government. When the IRS decided to crack down on Microsoft moving $39 billion in profits overseas, it used its tremendous resources to get the IRS to back down https://www.propublica.or…
  • @william_fitz William Fitzgerald on x
    fucking hell 'KPMG kept its promise to land a rock-bottom rate from the Puerto Rican gov. In exchange for Microsoft's promise to hire 46 employees, PR's secretary of state agreed to grant the co a tax rate that ranged from 0% - 2% for a period of 15 yrs' https://www.propublica.or…
  • @ericuman Eric Umansky on x
    @AndreaWNYC And then there's Microsoft. The IRS found Microsoft has played all sorts of games to avoid taxes. The company moved tens of billions in profits to a tiny factory it owns in Puerto Rico. Then what happened? Microsoft got the law changed. https://www.propublica.org/... …
  • @sesmith S.E. Smith on x
    Yet Bill Gates wants cookies for kicking some money to charity. https://www.propublica.org/...
  • @propublica @propublica on x
    “Most people, the 99%, they're afraid of the IRS,” said an attorney who works on large corporate audits. “The other 1%, they're not afraid. They make the IRS afraid of them.” https://www.propublica.org/...