Liberty Global Wants Redo of Its $110 Million Tax Refund Appeal

Liberty Global is asking for the entire Tenth Circuit to rehear its $110 million tax refund appeal, arguing that a panel decision against the telecommunications company will cause broad confusion for taxpayers.

In a 2-1 decision on April 21, the US Court of Appeals for the Tenth Circuit ruled that a series of transactions Liberty Global undertook to exploit a loophole in the 2017 tax law—an endeavor it dubbed “Project Soy"—were done solely to avoid taxes and, therefore, violated the “economic substance doctrine.”

“If uncorrected, the decision will transform the doctrine from a canon of statutory interpretation for confirming that ...