Liberty Global and the Economic Substance Doctrine

About this episode

Brian Reed discusses the economic substance doctrine in the context of the Liberty Global case and its implications.

Brian Reed of Alvarez & Marsal discusses the application of the economic substance doctrine in Liberty Global Inc. v. United States and the questions raised by the Tenth Circuit's interpretation. For more, read the following articles in Tax Notes: Otay Wants to Rebrief Dispute Over Basis Adjustment, IRS SaysLiberty Global Has Tax Pros Fretting Over Planning UncertaintyGovernment Wins Economic Substance Battle in Liberty Global** Credits Host: David D. Stewart Executive Prod...

People in this episode

Host: David D. Stewart

Guest: Brian Reed

Topics covered

• economic substance doctrine
• tax law
• Liberty Global case
• Tenth Circuit interpretation
• IRS regulations
• tax planning uncertainty

Keywords

• economic substance doctrine
• Liberty Global
• tax law
• Tenth Circuit
• IRS
• tax planning
• Alvarez & Marsal

Mentioned in this episode

Organizations: Alvarez & Marsal, Liberty Global Inc., United States, Tenth Circuit, IRS

Books & works: Tax Notes, Otay Wants to Rebrief Dispute Over Basis Adjustment, Liberty Global Has Tax Pros Fretting Over Planning Uncertainty, Government Wins Economic Substance Battle in Liberty Global

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