PODCAST

Planet of the APA: Liberty Global and the Future of Reg Invalidity

Inside International Tax, Episode 06-2022 | What are the implications of Liberty Global on challenges to the validity of Treasury regulations?

Gary Scanlon

Gary Scanlon

Principal, International Tax, Washington National Tax, KPMG US

Ronald Dabrowski

Ronald Dabrowski

Principal, Technical Deputy, Washington National Tax, KPMG US

Podcast overview

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.

 

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