Liberty Global and the Economic Substance Doctrine

Liberty Global and the Economic Substance Doctrine

June 5, 2026 · 37 min

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...

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