Counsel in Moore v. United States Analyze Implications of Supreme Court’s Tax Decision

Active

Program Number

34152

Program Date

2024-09-19

CLE Credits

Jeff Paravano and Andrew Grossman, tax counsel in the Supreme Court case, Moore v. United States, will present: “Implications of Moore v. United States”. Described by some as the most important constitutional tax case in more than half a century, Moore challenged the Ninth Circuit Court of Appeals’ determination that realization is not required for federal taxation of income without apportionment, as well as the constitutionality of the mandatory repatriation tax (“MRT”) enacted as part of the Tax Cuts and Jobs Act of 2017 that raised more than $340 billion in federal taxes. On June 20, 2024, the Supreme Court issued its opinion, upholding the constitutionality of the MRT in a narrow ruling, stating that the MRT taxes realized income and attributes that corporate income to shareholders.

Topics that will be discussed include, among others:

What are the implications of Moore with respect to the validity of federal taxation of wealth and appreciated assets?
Is Realization Required For Federal Taxation of Income without Apportionment?
What are the implications of Moore with respect to the validity of the tax on expatriation?
What are the broader implications of Moore?