Liberty Global Asks for Win in Foreign-Dividend Deduction Suit

Oct. 22, 2021, 10:40 PM

Telecommunications company Liberty Global asked for a win without a trial in its $109 million challenge to federal regulations that it says run contrary to a portion of the 2017 tax law.

The company’s lawsuit challenges temporary regulations (T.D. 9865) that limited tax deductions on certain foreign dividends under tax code Section 245A—a provision created under the 2017 tax law. The U.S. Treasury Department replaced the temporary rules with final rules in 2020.

“Treasury’s authority is to enforce the law—not, as it has done here, to re-write the law according to its own view of appropriate ...

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