With the action by Liberty Global in November of last year, we have the first challenge to the validity of the Temporary Regulations under section 245A. Loren and Steve discuss those regulations and some of the arguments we will see in that case.
Topics discussed:
- The section 245A deduction, the "GILTI doughnut hole," and what the Temporary Regulations do to address it
- Liberty Global's complaint
- Assessment of Liberty Global's arguments that the Temporary Regulations are invalid
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.