Liberty Global Inc. can’t claim a $241 million foreign tax credit for gains from its Japanese stock sale because proceeds in excess of the company’s overall foreign loss must be recognized as US taxable income, the Tenth Circuit said Friday.
The court affirmed a US Tax Court decision that blocked the credit for Liberty Global after it gained $3.25 billion on its stock sale of Jupiter Telecommunications Co.
Like the lower court, the US Court of Appeals for the Tenth Circuit said the language of the tax code limits the tax credit available to the telecommunications company. While the code ...