Skip to main content

tax break: Liberty Global: The First Challenge to the 245A Regs

tax break Podcast

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:

  1. The section 245A deduction, the "GILTI doughnut hole," and what the Temporary Regulations do to address it
  2. Liberty Global's complaint
  3. Assessment of Liberty Global's arguments that the Temporary Regulations are invalid

Questions? Contact us at

tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.

tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts: Apple Podcasts | Spotify | Google Podcasts | Stitcher | YouTube

*Former Miller & Chevalier attorney