DOJ Seeking $283M From Liberty Global Over Tax Dispute

Liberty Global underpaid federal income taxes by $236 million in 2019 when it used a plan codenamed Project Soy to exploit tax loopholes, said a complaint filed Friday (1:22-cv-02622) by the DOJ in U.S. District Court in Denver. DOJ is seeking the unpaid taxes along with $47 million in penalties, the complaint said. Project Soy involved a series of transfers among Liberty Global international subsidiaries aimed at taking advantage of provisions of the 2017 Tax Cuts and Jobs Act (TCJA) to avoid paying capital gains and other taxes on gains from Liberty Global’s interest in Belgian company TGH. Liberty has challenged changes to the tax laws intended to close the loophole, and DOJ has a separate case (1:20-cv-03501-RBJ) arguing that Liberty violated tax laws with the plan.