Liberty Global Decision and the Economic Substance Doctrine

Brian Reed of Alvarez & Marsal discusses the application of the economic substance doctrine in Liberty Global Inc. v. United States and the questions raised by the Tenth Circuit's interpretation. For more, read the following articles in Tax Notes : Otay Wants to Rebrief Dispute Over Basis Adjustment, IRS Says Liberty Global Has Tax Pros Fretting Over Planning Uncertainty Government Wins Economic…