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?
Protect your practice from the ethical vulnerabilities of AI by mastering Model Rules 1.1 and 1.5. T...
My contract was terminated and the contracting officer did not pay my invoices – what can I do...
Social media has become a critical marketing and customer engagement channel for legal firms, banks,...
This program provides a comprehensive framework for integrating Borderline Personality Disorder (BPD...
This program will address the ethical obligations of Lawyer Advocates representing clients in arbitr...
This program examines the role of psychosocial evaluations in spousal abuse-based immigration petiti...
This program provides attorneys with a comprehensive framework for incorporating psychosocial evalua...
This course will provide a detailed overview of the Medicare Secondary Payer act as well as provide ...
This program examines the complex intersection of criminal convictions and immigration law under the...
Contracting with the Federal Government is not like a business deal between two companies or a contr...