They've got a lot better. Their link profile is still stuffed with keyword anchored splogs and shit but penguin has only served to solidify their position by knocking of the comp.
They get a pass because Google see's them as a good fit for the SERPs.
Unless they end up with a public relations issue calling them out on their SEO practise the techniques that are penalising some sites are working better than ever for sites like MS.
