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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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June 12, 2026
Biz Groups Back Liberty Global In $2.4B Tax Substance Fight
The Tenth Circuit should reconsider its decision denying telecommunications company Liberty Global a $2.4 billion income deduction, the U.S. Chamber of Commerce and other groups said, arguing the court excessively broadened a rule that is meant to disallow tax benefits in limited situations.
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June 08, 2026
Liberty Global Seeks Rehearing In $2.4B Tax Substance Fight
Telecommunications firm Liberty Global wants another shot at showing the Tenth Circuit that it's entitled to a $2.4 billion deduction linked to transactions with foreign affiliates, claiming the court misapplied a rule that can disallow tax benefits from transactions that lack economic substance.
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April 22, 2026
Liberty Global Loses $2.4B Tax Substance Fight In 10th Circ.
Telecommunications giant Liberty Global is not entitled to a $2.4 billion deduction tied to transactions with its foreign affiliates, the Tenth Circuit ruled in a long-awaited opinion, siding with the U.S. government in finding the arrangement is a tax shelter lacking economic substance.
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January 02, 2026
Top Federal Tax Cases To Watch In 2026
The application of self-employment taxes to limited partners, the economic substance doctrine's threshold and the question of whether IRS penalties need a jury's deliberation are topics federal courts likely will examine in coming decisions. Here, Law360 reviews the top federal tax cases to watch in the coming year.
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January 02, 2026
Top International Tax Cases To Watch In 2026
Major multinational corporations such as McKesson and Coca-Cola will continue to litigate high-stakes international tax cases in 2026, including transfer pricing disputes with billions of dollars on the line and fights over whether regulations exceed the government's authority. Here, Law360 looks at four key international tax cases to follow in the new year.
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July 03, 2025
Top International Tax Cases To Watch In 2nd Half Of 2025
Major multinational corporations such as 3M and Coca-Cola are expected to continue litigating high-stakes international tax cases in the second half of 2025, including disputes that could test the application of the U.S. Supreme Court's ruling that gutted judicial deference to agencies. Here, Law360 looks at seven key cases to follow the rest of the year.
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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.