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?
Tracking and using consumer’s data without consent is a high stakes game. From class actions t...
This CLE program covers the most recent changes affecting IRS information reporting, with emphasis o...
This presentation teaches attorneys how to deliver memorized text—especially openings and clos...
Protect clients and yourself by knowing some of the more common ethical issues that can affect your ...
Evidence Demystified Part 2 covers key concepts in the law of evidence, focusing on witnesses, credi...
Law firms across the country are rethinking traditional staffing models to stay competitive, reduce ...
Mary Beth O'Connor will describe her personal history of 20 years of drug use and 30+ years of sobri...
A litigator’s role is to shape how key decision-makers - judges, jurors, and opposing counsel ...
This program examines the strategy and artistry of closing argument, positioning it as a lawyer&rsqu...
This presentation explores courtroom staging—how movement, spatial awareness, posture, and pre...