Tag: TCJA

Liberty Global – Economic Substance Case

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

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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ETA 2026 – Switching from Inclusion to Exclusion Planning for the Estate Tax

Estate and Gift Tax, Estate Planning, Income Tax, Tax

Currently (and since the Tax Cuts and Jobs Act of 2017), we, like many other practitioners, have seen an incredible uptick in inclusion planning[1] instead of the traditional exclusion planning (getting assets out of one’s taxable estate). A primary driving force for this major shift was the essential doubling of the estate tax exemption (from…
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