U.S. Tax Review: Liberty Global Amici, Section 6038 and Amgen Penalties, and Finalized FIRPTA Regs

By: Larissa B. Neumann , Julia Ushakova-Stein , Michael Knobler

In this installment of U.S. Tax Review, tax partners Larissa Neumann, Julia Ushakova-Stein and Mike Knobler review Liberty Global amicus briefs regarding the economic substance doctrine, describe final regulations governing the determination of whether a real estate investment trust is domestically controlled, review court cases involving the assessment and supervisory approval of penalties, and offer updates on the Corporate Transparency Act and challenges to global intangible low-taxed income regs.

Read the full commentary and analysis in Tax Notes.