A U.S. district court denied a company's dividends-received deduction under IRC Section 245A after applying the codified economic substance doctrine (the Codified ESD) under IRC Section 7701(o).In reaching its conclusion, the court took a broad view of the Codified ESD, rejecting the company's argument that the doctrine was limited to transactions to which it is "relevant."The decision represents a timely reminder to taxpayers about the role and importance of the common law ESD, including its application to multi-step transactions.On October 31, 2023, Senior Judge R. Brooke Jackson of the United States District Court for the District of Colorado (the Court)...