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?
AI is impacting virtually every corner of practicing law. Increasing AI usage has revealed myriad ri...
This program provides attorneys with a foundational understanding of the name, image, and likeness (...
Aligning Your Legal Career with Your Values, explores the profound impact of values alignment on ind...
This program examines critical 2025-2026 developments in patent eligibility for software and AI inve...
Artificial intelligence is already reshaping legal practice, from research and drafting to litigatio...
The landscape of global finance is undergoing a seismic shift as traditional assets migrate to the b...
Contracting with the Federal Government is not like a business deal between two companies or a contr...
This program reframes domestic violence through the lens of “intimate terrorism,” equipp...
This program focuses on asylum claims based on sexual orientation, addressing the unique clinical, c...
Electronic information is a common feature of criminal investigations and prosecutions, both federal...