Major Temporary International Tax Deduction Rules Invalid (1)

Temporary rules that the Treasury Department said were issued to protect Congress’s international tax system as well as billions of dollars in revenue are invalid because they weren’t issued properly, a federal court ruled.

Telecommunications company Liberty Global Inc. brought the lawsuit at the U.S. District Court for the District of Colorado challenging 2019 temporary regulations (T.D. 9865) that applied retroactively. The rules addressed deductions under tax code Section 245A tied to certain dividends.

The decision followed Judge R. Brooke Jackson expressing skepticism during February oral arguments over whether the rules went through the proper procedures. ...