Economic Substance and Liberty Global: Are There Limitations to the ESD?
Very good discussion
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Sessions
Richard M. Lipton
Session 1 —54 mins
Economic Substance and Liberty Global: Are There Limitations to the ESD? (Jan 2025)
The district court's decision in Liberty Global, combined with various statements from government officials, appears to indicate an expansion of the economic substance doctrine (ESD). Explore the history, application and limitations of the doctrine, with Liberty Global serving as the background for discussion.
Originally presented: Dec 2024 Taxation Conference: Day 1 - Focus on Business Planning
Richard M. Lipton,
Baker McKenzie LLP - Dallas, TX