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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…

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IRS 45Z Hearing Recap: What Treasury’s Questions Signal for the Final Clean Fuel Credit Rule

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USMCA Joint Review Triggers Annual Reviews but Does Not Alter Current Trade Benefits

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Reasonable Standards for Contract Interpretations Under the CISG

The United Nations ("UN") Convention on Contracts for the International Sale of Good ("CISG") offers the promise of harmonizing internationa

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