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Tax Court › Foreign Tax Credits › Tax Liability

Jones Day

U.S. Tax Court Invokes Loper Bright for the First Time

Jones Day on

The U.S. Tax Court allows a dividend-received deduction ("DRD") for a Section 78 gross-up while also disallowing foreign tax credits in its first application of Loper Bright....more

Cadwalader, Wickersham & Taft LLP

Liberty Global to Appeal Its Foreign Tax Credit Tax Court Loss

Cadwalader, Wickersham & Taft LLP on

Liberty Global has announced that it will challenge the November 2023 Tax Court finding that the company had incorrectly boosted its foreign tax credits by failing to account for gains that exceeded the total foreign loss on...more

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