The contract between the IRS and Quinn Emmanuel was signed May 19, 2014, with a completion date of December 31, 2016, and a payment obligation of $2,185,500, according to a website maintained by the Office of Management and Budget.

The law firm was retained by the IRS to help it examine the Corporate federal tax returns filed by Microsoft between 2004 and 2009.

The transfer pricing issues that the audit may involve include a cost sharing agreement (CSA) with respect to the sufficiency of buy-in payments by an offshore affiliate of Microsoft's in exchange for licensing intangibles.

[1][2][3][4][5][6][7][8] On September 10, 2014 ZDNet reported that Microsoft was held in contempt of court after refusing to hand over foreign data.

[9][10] On December 24, 2014, the Seattle Times reported that the IRS sued former Microsoft CEO Steve Ballmer, Craig Mundie, Jeff Raikes, Jim Allchin, Orlando Ayala and David Guenther in an effort to compel them to testify in Microsoft's corporate tax audit.