Documenting Business Purpose After IRS' 10th Circ. Win
By Carina Federico and Starling Marshall ( May 6, 2026, 5:44 PM EDT) -- In a highly anticipated and long awaited decision, on April 21 the U.S. Court of Appeals for the Tenth Circuit ruled in favor of the IRS in Liberty Global Inc. v. U.S. The court held that Liberty Global's disputed transactions lacked economic substance and that the economic substance doctrine did not require a threshold relevancy determination to be applied....
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