IT之家 9 月 30 日消息，据纽约时报报道，马克 · 扎克伯格（Mark Zuckerberg）宣称，Meta 在人工智能领域的布局大获全胜。“笔者在 AI 领域的投入，正在全面提速所有核心业务板块，”他向投资人表示，“无论是自身业务的发展势头，还是全行业的演进趋势，都印证了这一投资决策的正确性。”
不过在报税环节，Meta 向美国国家税务局 IRS 展现的却是另一番景象。据四位了解该公司运营内情的人士透露，Meta 向税务部门辩称，其 AI 数据中心本质上只是一项随时可能面临失败的庞大实验。
Meta 此举意在套用一项专为研发与实验设立的税收抵免政策。Meta 以此为其数据中心扩张申请了数十亿美元的税收减免。
“将 AI 数据中心包装成实验性质，这种做法可以说是相当离谱且大胆的，”咨询机构 BPM 专注研发税收抵免业务的合伙人安德烈 · 舍夫丘克（Andre Shevchuck）指出。
事实上，Meta 自家的财务会计人员也深知该策略缺乏充足的法律支撑。这家科技巨头在证券申报文件的细枝末节中坦言，由于“公司在研发税收抵免维度存在不确定性”，这笔高达数十亿美元的节税额度面临被 IRS 推翻的重大风险。
Meta 的具体操作如下：在税务申报中，该公司将其耗资数十亿美元的超大规模数据中心归类为“试制模型”。这项设立于 20 世纪 80 年代、旨在激励创新的税收抵免政策规定，企业采购的耗材物料可以享受税费返还，但核心前提是这些物料必须投入到实验性研发中，而不得用于常规商业运营。Meta 据此主张，其向英伟达等供应商采购的高昂 AI 计算芯片，属于上述实验的一部分，理应享受由公共财政（纳税人）买单的税务减免。
这一策略在 Meta 内部财务部门引发了担忧。此前，IRS 就曾多次对企业将常规物资采购纳入该项抵免的做法提出异议。尽管涵盖其他科技巨头在内的数千家企业也在享受研发税收抵免，但它们的抵免额绝大多数来自支付给研发人员与工程师的薪酬 —— 即真正承担创新工作的人力成本，而非大宗硬件采购。
财报文件表明，Meta 自两年前开始将数据中心支出纳入该税收抵免范畴。自此之后，公司凭此取得的税收减免额度一路飙升，仅去年一年就为其直接省下了近 40 亿美元（IT之家注：现汇率约合 268.71 亿元人民币）税款。该媒体查阅公开证券申报记录发现，Meta 当下已成为所有美股上市公司中该项税收优惠的最大受益者。
此前，Meta 就曾因滥用该项税收优惠而与 IRS 卷入一场数额庞大的税务纠纷 —— 该公司曾试图以此冲抵其首席执行官数十亿美元的天价薪酬。法庭文件表明，Meta 曾在 2013 年辩称，扎克伯格行使的 41 亿美元（现汇率约合 275.43 亿元人民币）股票期权属于研发支出，理由是他参与主导开发了诸如“动态消息”等核心软件。当下，IRS 正借助司法途径追缴 Meta 借此避税所得的 3.55 亿美元（现汇率约合 23.85 亿元人民币）款项。
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IT之家 reported on September 30 that, according to The New York Times, Mark Zuckerberg has declared that Meta's layout in the field of artificial intelligence has achieved a major victory. "My investment in the AI field is accelerating all core business segments at full speed," he told investors. "Both the momentum of our own business and the evolution trend of the entire industry confirm the correctness of this investment decision."
However, when it comes to tax filing, Meta presented a completely different picture to the U.S. Internal Revenue Service (IRS). According to four people familiar with the company's operations, Meta argued to tax authorities that its AI data centers are essentially a massive experiment that could fail at any time.
Meta's move is intended to take advantage of a tax credit policy specifically established for research and development and experimentation. Meta used this to apply for billions of dollars in tax reductions for its data center expansion.
"Packaging AI data centers as experimental in nature is quite outrageous and bold," noted Andre Shevchuck, a partner at consulting firm BPM specializing in R&D tax credit services.
In fact, Meta's own financial accounting personnel are well aware that this strategy lacks sufficient legal support. The tech giant admitted in the fine print of its securities filings that, due to "uncertainty in the company's R&D tax credit dimension," this multi-billion-dollar tax savings face significant risk of being overturned by the IRS.
Meta's specific approach is as follows: In its tax filings, the company classified its multi-billion-dollar hyperscale data centers as "pilot models." This tax credit, established in the 1980s to incentivize innovation, stipulates that companies can receive tax refunds on consumable materials purchased, but the core prerequisite is that these materials must be invested in experimental R&D and must not be used for routine commercial operations. Based on this, Meta claimed that the expensive AI computing chips it purchased from suppliers such as Nvidia are part of the aforementioned experiment and should enjoy tax reductions paid for by public finances (taxpayers).
This strategy has raised concerns within Meta's internal finance department. Previously, the IRS had repeatedly objected to companies including routine material purchases under this credit. Although thousands of companies, including other tech giants, also enjoy R&D tax credits, the vast majority of their credits come from compensation paid to R&D personnel and engineers — that is, the labor costs of those truly undertaking innovative work, rather than bulk hardware purchases.
Financial filings indicate that Meta began including data center expenditures under this tax credit two years ago. Since then, the company's tax reductions obtained through this approach have soared, saving it nearly $4 billion directly in taxes last year alone (IT之家 note: approximately 26.871 billion RMB at current exchange rates). According to a review of public securities filings by the media outlet, Meta has now become the largest beneficiary of this tax incentive among all U.S.-listed companies.
Previously, Meta had been involved in a massive tax dispute with the IRS over abuse of this tax credit — the company had attempted to use it to offset the CEO's multi-billion-dollar astronomical compensation. Court documents show that Meta argued in 2013 that the $4.1 billion (approximately 27.543 billion RMB at current exchange rates) in stock options exercised by Zuckerberg constituted R&D expenditures, on the grounds that he participated in leading the development of core software such as "News Feed." Currently, the IRS is seeking through judicial channels to recover the $355 million (approximately 2.385 billion RMB at current exchange rates) that Meta avoided paying in taxes through this scheme.
