The Liberty Global case is another example of the recent trend of courts rejecting the concept of tax exceptionalism. Liberty Global may just be the tip of the iceberg…or the tip of the spear. What are the implications of Liberty Global on reg invalidity? Why are we seeing more challenges to Treasury Regulations? Are the recently issued foreign tax credit regulations subject to challenge under the Administrative Procedure Act (APA) or Chevron?
Our host Gary Scanlon welcomes KPMG Tax professional Ron Dabrowski to discuss the impact of Liberty Global, the APA, and challenges to the validity of Treasury regulations.