LegalAugust 12, 2026

Regulatory challenges and the economic substance doctrine: Implications from Liberty Global

This webinar replay explores the implications of Liberty Global for Treasury regulations and the economic substance doctrine (ESD).

Presented by Bret Wells, this insightful webinar examines the district court’s initial ruling invalidating temporary Treasury regulations—regulations that would have produced the same outcome later reached by both the court and the Tenth Circuit under the ESD (denial of the taxpayer’s refund claim). The requirements for agency rulemaking and the role of temporary Treasury regulations are discussed, followed by an analysis of the ESD’s “relevancy” requirement and its roots in the absurdity canon of construction.

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