Treasury’s Dividend-Deduction Rules Tested in Tax Refund Lawsuit (1)

Nov. 30, 2020, 5:26 PMUpdated: Nov. 30, 2020, 9:39 PM

A telecommunications company has sued for a $109 million refund of taxes, penalties, and interest in a legal challenge to temporary regulations that limit the deduction taxpayers can get on certain foreign dividends.

Liberty Global Inc. alleged it was entitled to a deduction under tax code Section 245A after an affiliate sold an interest in a publicly-traded company to it, which generated taxable income. The telecommunications parent company claimed that temporary regulations (T.D. 9865) wrongly denied the company the “vast majority” of the deduction it was entitled to for tax year 2018 as a result of ...

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