In Liberty Global, the Tenth Circuit Leaves Taxpayers with an Opinion with Unresolved Questions
On April 21, 2026, in Liberty Global, Inc. v. United States , the Tenth Circuit held that the economic substance doctrine was “relevant” and applied to deny Liberty Global, Inc. a $2.4 billion deduction and imposed a 40% penalty with respect to a transaction known as “Project Soy”. The Tenth Circuit’s decision was highly anticipated, as various courts have d
