Podcast: Illinois Tool Works Inc. & Subsidiaries v. Commissioner of Internal Revenue
Liberty Global Inc. (“LGI”) avoided tax from the sale of a Belgian subsidiary by claiming a dividends received deduction for the entire amount of $2.6 billion in gain. The government challenged this result on economic...more
Liberty Global Inc. ("LGI") and the Department of Justice are in fierce litigation over the application of the economic substance and step transaction doctrines to a transaction for which LGI claimed a dividends received...more
Earlier this month, Massachusetts Mutual Life Insurance Company (MassMutual), represented by Skadden, won a federal appeal permitting the company to deduct policyholder dividends in the year the dividends were declared, even...more