Liberty Global’s $110 Million Refund Appeal Should Fail, US Says

Telecommunications giant Liberty Global Inc. was properly denied its $110 million tax refund claim because its business dealings supporting the claim amounted to a tax avoidance scheme, the Justice Department told a federal appeals court.

The US government briefed the US Court of Appeals for the Tenth Circuit on Thursday, defending a district court’s decision to apply the economic substance doctrine in order to disregard a portion of LGI’s tax strategy, sinking its refund claim in turn. The doctrine requires a transaction to have some purpose besides reducing tax liability, and cause some change in a firm’s economic position, in ...