Liberty Global v. United States
Case Number:
23-1410
Court:
Nature of Suit:
Companies
- American Fuel & Petrochemical Manufacturers
- Liberty Global Inc.
- National Association of Manufacturers
- National Foreign Trade Council
- National Taxpayers Union
Sectors & Industries:
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July 03, 2025
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July 03, 2025
Top Federal Tax Cases To Watch In 2nd Half Of 2025
In the second half of this year, tax professionals will be keeping an eye on suits challenging the IRS' handling of employee retention tax credits and litigation over new microcaptive insurance regulations, as well as disputes over civil fraud penalties. Here, Law360 looks at the top federal tax cases to monitor during the rest of 2025.
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January 01, 2025
Top International Tax Cases To Watch In 2025
Major multinational corporations such as 3M and Coca-Cola will continue to litigate high-stakes international tax cases during 2025, including transfer pricing disputes with billions of dollars on the line and fights against regulations that allegedly exceed the government's authority. Here, Law360 looks at six key international tax cases to follow in the new year.
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January 01, 2025
Top Federal Tax Cases To Watch In 2025
Over the next year, tax practitioners will be closely monitoring suits that challenge the IRS' use of the economic substance doctrine, take advantage of the U.S. Supreme Court's landmark decision curbing federal agencies' regulatory authority and dispute the government's handling of worker retention credits. Here, Law360 looks at key federal tax cases to follow in 2025.
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December 11, 2024
Exxon Tax Ruling Doesn't Help Liberty Global, 10th Circ. Told
Liberty Global cannot use a recent ruling that allowed Exxon Mobil a tax deduction for interest payments to claim a deduction for dividends that arose from its intragroup shuffling of a Belgian affiliate, the U.S. government told the Tenth Circuit on Wednesday.
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December 10, 2024
Exxon's Tax Win Sets Path For Liberty Global, 10th Circ. Told
A ruling allowing Exxon Mobil a U.S. tax deduction for interest expenses in its natural gas deal with Qatar confirms that Liberty Global is entitled to a deduction related to its sale of a Belgian affiliate, an attorney for the telecommunications company told the Tenth Circuit.
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November 19, 2024
Liberty Global Tax Break Based On Void Moves, 10th Circ. Told
The economic substance doctrine is broad and can invalidate telecommunications company Liberty Global's transaction that led to a $2.4 billion deduction because steps taken to maximize the tax break lacked business purpose, a government attorney told the Tenth Circuit on Tuesday.
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November 07, 2024
Varian Not Relevant In Liberty Global Case, US Tells 10th Circ.
A U.S. Tax Court decision that granted medical device company Varian Medical Systems a deduction for dividends received from foreign subsidiaries does not support Liberty Global's claims to a $110 million tax refund, the federal government told the Tenth Circuit on Thursday.
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August 02, 2024
Liberty Global's $110M Tax Refund Kosher, 10th Circ. Told
The IRS is trying to block Liberty Global's bid for a $110 million tax refund by improperly using a legal doctrine requiring transactions to have economic substance, the telecommunications giant told the Tenth Circuit, arguing it was allowed to make tax-driven choices in the transactions at issue.
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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.