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 agents — autonomous systems capable of planning, deciding, and acting independently across ...
Adverse and derogatory information often has devastating effects on a contractor's ability to win co...
New York City’s new Non-Primary Residence Property Surcharge—commonly known as the pied-...
Class action litigation continues to expand in both number of filings and monetary exposure, with se...
Class action waivers in arbitration agreements remain enforceable, but a decade of U.S. Supreme Cour...
Data privacy remains one of the most rapid areas of growth in the class action space. Plaintiffs con...
During this course, you will learn about best practices and strategies for retaining intellectual pr...
Class action litigation presents significant legal and business challenges for employers and corpora...
This program provides trial attorneys with a thorough grounding in the three principal currency repo...
"Artificial Intelligence and the Practice of Law" (updated through 2026), is a 50-slide primer desig...