Complimentary Webinar
Regulatory Challenges and the Economic Substance Doctrine: Implications from Liberty Global
Date: August 5, 2026
Time: 12:00pm EDT
Join us for Regulatory Challenges and the Economic Substance Doctrine: Implications from Liberty Global on Wednesday, August 5, 2026, at 12pm ET for a live discussion exploring 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). We’ll then discuss the requirements for agency rulemaking and the role of temporary Treasury regulations, followed by an analysis of the ESD’s “relevancy” requirement and its roots in the absurdity canon of construction.
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Speaker
Bret Wells
Bret Wells is the John Mixon Chair and Professor of Law with the University of Houston Law Center and teaches in the federal tax area.
Professor Wells is a co-author of on several leading casebooks, a treatise on international taxation, and has written extensively on federal income taxation matters. Prior to joining the University of Houston Law Center, Mr. Wells was an executive officer in one largest oilfield service companies in the world with operations in over 60 countries.
Professor Wells holds a Juris Doctorate from the University of Texas School of Law (cum laude, 1989). Mr. Wells also holds a B.B.A. in Accounting from Southwestern University (summa cum laude, 1987). He is licensed to practice law and is a Certified Public Accountant in the state of Texas.
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