Will The Economic Substance Doctrine And Its Potential Tax Consequences Swallow Transfer Pricing? [Forbes]
Liberty Global Ltd. - Class A Common Shares (LBTYA)
Last liberty global ltd. - class a common shares earnings: 11/7 04:15 pm
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Source: Forbes
To the surprise of many observers, a U.S. district court that had invalidated the temporary section 245A regulations in 2022 granted the government's motion for summary judgment in Liberty Global Inc. v. United States , No. 1:20-cv-03501 (D. Colo. 2023). The district court order, issued by Judge R. Brooke Jackson of the U.S. District Court for the District of Colorado, endorsed an expansive interpretation of the economic substance doctrine codified in section 7701(o) The decision, which Liberty Global almost immediately appealed to the Tenth Circuit, has rattled tax advisers and multinationals and led to predictions that the economic substance doctrine will become a recurring feature in transfer pricing disputes. As a non-textualist, judicially invented antiavoidance measure, the economic substance doctrine has always been controversial, and it remained so after its codification in 2010. But the controversy only intensified after the IRS's Large Business and International Divisio
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LBTYA
Sec Filings
- 4/17/24 - Form 4
- 4/15/24 - Form 144
- 4/9/24 - Form 8-K
- LBTYA's page on the SEC website