With the action by Liberty Global in November of last year, we have the first challenge to the validity of the Temporary Regulations under section 245A. We discuss those regulations and some of the arguments we will see in that case.
Topics discussed:1. The section 245A deduction, the “GILTI donut hole,” and what the Temporary Regulations do to address that “donut hole”2. Liberty Global’s complaint3. Assessment of Liberty Global’s arguments that the Temporary Regulations are invalid
...
With the action by Liberty Global in November of last year, we have the first challenge to the validity of the Temporary Regulations under section 245A. We discuss those regulations and some of the arguments we will see in that case.
Topics discussed:
1. The section 245A deduction, the “GILTI donut hole,” and what the Temporary Regulations do to address that “donut hole”
2. Liberty Global’s complaint
3. Assessment of Liberty Global’s arguments that the Temporary Regulations are invalid
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Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you’ll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.
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