Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Last October, a District Court in Colorado turned the economic substance doctrine on its head. In Liberty Global, Inc. v. US, a District Court granted the Government’s motion for summary judgement and found that contrary to...more
In ongoing litigation between the government and Liberty Global Inc. (“Liberty Global”), Liberty Global has appealed a district court’s decision that ruled in favor of the government to the Tenth Circuit. We have previously...more
The Tax Court has invited amicus briefs and will address the codified meaning of the economic substance doctrine after increased IRS use of the doctrine to challenge taxpayer transactions. In a July 19, 2024, order in...more
The book has closed on 2023, but several recent tax-related rulings are sure to have ripple effects into 2024 and beyond—particularly with respect to transfer pricing and foreign tax credits. Here are five cases that will...more
Liberty Global Inc. (“LGI”) avoided tax from the sale of a Belgian subsidiary by claiming a dividends received deduction for the entire amount of $2.6 billion in gain. The government challenged this result on economic...more
What a Mess- A “perfect storm” may be defined as a critical state of affairs arising from the convergence of a number of negative factors, often after the unexpected introduction of some catalytic event. The situation...more