Liberty Global v. United States

  1. July 18, 2024

    Top International Tax Cases To Watch In The 2nd Half Of 2024

    Tax attorneys will be tracking several high-stakes cases in the second half of 2024 that could define the bounds of the IRS' ability to craft regulations or lodge direct challenges aimed at what it sees as the tax avoidance maneuvers of multinational corporations. Here, Law360 looks at key international tax cases to follow during the rest of the year.

  2. July 05, 2024

    Top Federal Tax Cases To Watch In The 2nd Half Of 2024

    In the coming months, the U.S. Treasury and the IRS will defend rules designed to go after what they consider as abusive tax practices, including the economic substance doctrine, the Corporate Transparency Act and the moratorium on employee retention tax credits. Here, Law360 looks at key federal tax cases to watch in the rest of 2024.

  3. June 27, 2024

    IRS Tells 10th Circ. To Deny Liberty Global's $110M Refund Bid

    The U.S. government urged the Tenth Circuit on Thursday to reject telecommunication giant Liberty Global's push for a $110 million tax refund, arguing a lower court correctly deduced that the company's business restructurings were carried out solely to avoid tax.

  4. May 07, 2024

    Biz Orgs. Ask 10th Circ. To Toss Economic Substance Ruling

    The Tenth Circuit must not uphold a Colorado federal court's ruling that it didn't need to determine whether economic substance doctrine was relevant before disallowing an intercompany transaction by Liberty Global Inc., three business groups told the Tenth Circuit in briefs Tuesday.

  5. May 06, 2024

    10th Circ. Urged To Alter Substance Finding In Liberty Global

    To preserve the stability of federal tax law, the Tenth Circuit should reverse a lower court's finding that it needn't determine the economic substance doctrine is relevant before disallowing a transaction's tax benefits, the National Foreign Trade Council said Monday, supporting telecommunications firm Liberty Global.

  6. May 01, 2024

    Liberty Global Defends $109M Tax Refund Bid In 10th Circ.

    Telecommunications giant Liberty Global urged the Tenth Circuit to revive the company's $109 million tax refund bid, arguing a lower court rejected the claim by wrongly disregarding intercompany transactions that are permitted under legislation involving the repatriation of foreign profits.

  7. January 03, 2024

    10th Circ. To Hear Liberty Global's $109M Tax Refund Case

    Telecommunications company Liberty Global Inc. has appealed to the Tenth Circuit regarding a Colorado federal court's decision that denied the company a $109 million tax refund claim by concluding that underlying intercompany transactions lacked economic substance other than to significantly reduce its tax bill.