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GAO Repeats Protective Order Warning

Client Alert | less than 1 min read | 04.03.08

In denying the motion for reconsideration of its dismissal of the protest in PWC Logistics Servs. (Mar. 31, 2008) for breach of the protective order by the client retaining for a week protected material and distributing it within the company, GAO repeated that this case is to serve as a warning to other protestors: if the client receives from its attorneys any materials that are marked as subject to protective order, they are immediately to close and return or destroy the materials, and their attorneys are to provide prompt notice of the violation.

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Client Alert | 3 min read | 07.13.26

Amici Rally Behind Liberty Global, Urging Tenth Circuit to Rein in Economic Substance Doctrine

Following the 10th Circuit's April 21, 2026, decision affirming the disallowance of Liberty Global’s $2.4 billion deduction under the codified economic substance doctrine, I.R.C. § 7701(o), Liberty Global filed a petition for panel rehearing or rehearing en banc on June 5, 2026. That petition has since drawn significant amicus support from various industry groups representing large taxpayers, as discussed below....