step transaction Archives

Liberty Global – Economic Substance Case

Cases, Court of Appeals, Income Tax, Tax, Tax Controversy, Uncategorized

Sep 28, 2026

Tax lawyers routinely test proposed transactions against the technical requirements of the Internal Revenue Code. The Tenth Circuit’s recent decision in Liberty Global, Inc. v. United States[1] is a reminder that literal compliance may not always end the analysis. In Liberty Global, the court applied the codified economic substance doctrine to deny a claimed §…
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GSS Holdings – A Reminder on Economic Substance and Step Transaction

Cases, Court of Appeals, Income Tax, Tax, Tax Controversy

Oct 4, 2023

Most tax law is made up of very detailed statutes, regulations, case law, and other guidance. Layered on top of that body of law are a number of “judicial doctrines” that seek to serve as a backstop to formalistic analyses that could result in unintended tax results, allow taxpayers to place the form of transactions…
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Tag: step transaction

Liberty Global – Economic Substance Case

GSS Holdings – A Reminder on Economic Substance and Step Transaction

Directions

Liberty Global – Economic Substance Case

Income Tax Planning with Non-Grantor Trusts After OBBBA

Tax Court Rejects Offer in Compromise Despite Extraordinary Personal Circumstances