Question: SoonerCo. is engaged in a transfer pricing scheme with its international affiliate. It sells goods from the foreign affiliate to the US company at a

SoonerCo. is engaged in a transfer pricing scheme with its international affiliate. It sells goods from the foreign affiliate to the US company at a high price to record more income in the lower tax foreign jurisdiction. This scheme reduces U.S. taxes by $50 million each year. SoonerCo. believes it is 75% likely that it can successfully defend its transfer pricing scheme in court on its technical merits if the IRS chooses to perform an audit. If the IRS challenges its scheme, Sooner believes the following are the possible outcomes: Sooner wins the case and retains the $50 million of tax savings: 30%; Sooner settles with the IRS to pay $10 million: $30%; Sooner settles with the IRS to pay $25 million: 25%; Sooner loses the case and has to pay $50 million: 15%. Sooner believes an audit is unlikely based on prior experience. How much, if any, tax liability (unrecognized tax benefit) should Sooner record for this uncertain tax position? Explain

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