ExxonMobil Deduction Bolsters Refund Claim, Liberty Global Says

Liberty Global Inc. told the Tenth Circuit that a recent ruling reviving Exxon Mobil Corp.‘s tax deduction claim for production payments to Qatar supports the telecommunication company’s case seeking a $110 million refund from the IRS.

Liberty Global sued for a $110 million refund after the IRS denied its claimed deduction under Section 245A on the grounds that the business had exploited a loophole in the 2017 Republican tax law to improperly avoid paying GILTI and capital gains taxes. It appealed to the US Court of Appeals for the Tenth Circuit after a Colorado district court backed the IRS ...