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TBL LICENSING v. COMMISSIONER OF INTERNAL REVENUE

No. 22-1783.

82 F.4th 12 (2023)

TBL LICENSING LLC, f/k/a The Timberland Company, and subsidiaries (a consolidated group), Petitioner, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent, Appellee.

United States Court of Appeals, First Circuit.

September 8, 2023.

Attorney(s) appearing for the Case

Shay Dvoretzky , with whom Christopher Bowers , Nathan Wacker , Parker Rider-Longmaid , Sylvia O. Tsakos , Hanaa Khan , Skadden, Arps, Slate, Meagher & Flom LLP, James Preston Fuller , and Fenwick & West LLP were on brief, for appellant.

Judith A. Hagley , Tax Division, Department of Justice, with whom David A. Hubbert , Deputy Assistant Attorney General, Tax Division, Department of Justice, Francesca Ugolini , Tax Division, Department of Justice, and Jacob Christensen , Tax Division, Department of Justice, were on brief, for appellee.

Before Kayatta, Lipez, and Gelpí, Circuit Judges.

In 2011, TBL Licensing LLC ("TBL") transferred intangible property worth approximately $1.5 billion to an affiliated foreign corporation. The transfer occurred in the context of a corporate reorganization involving an exchange as described in section 361 of the Internal Revenue Code.1 TBL took...

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