US court denies Liberty Global's claim for the IRC Section 245A dividends-received deduction on economic substance doctrine grounds
|Tax Alerts, Legislation & Policy, Na ...|United States
A U.S. district court denied a company's dividends-received deduction under IRC Section 245A after applying the codified economic substance doctrine (the Codified ESD) under IRC Section 7701(o).
In reaching its conclusion, the court took a broad view of the Codified ESD, rejecting the company's argument that the doctrine was limited to transactions to which it is "relevant."
The decision represents a timely reminder to taxpayers about the role and importance of the common law ESD, including its ap…
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