Tax Bytes: Week of September 22, 2025 | Eversheds Sutherland (US) LLP
Welcome to this week’s edition of Tax Bytes. Our team of tax lawyers is actively monitoring for federal and international tax developments and issues of note. Each week we pull together the items we deem most important to provide updates you need to know for your business.
Tax developments
Tenth Circuit blocks Liberty Global’s $240M foreign tax credit claim
The Tenth Circuit recently affirmed the Tax Court’s denial of Liberty Global Inc.’s $240 million foreign tax credit (FTC) claim stemming from the recapture of an overall foreign loss (OFL) triggered by the $3.9 billion sale of its Japanese controlled foreign corporation (CFC), Jupiter Telecommunications (J:COM).1 The decision reinforces the limitations on the availability of foreign tax credits and clarifies that taxpayers cannot expand creditability beyond the strict confines of the statutory sourcing rules.
Read the full alert here.
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