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?
Objections are among the most powerful — and most misunderstood — tools in a trial lawye...
As the largest purchaser of goods and services in the world, the United States Government requires f...
Adverse and derogatory information often has devastating effects on a contractor's ability to win co...
Have you felt overwhelmed by the amount of technology available to family lawyers? We'll get to know...
This dynamic CLE presentation challenges trial lawyers to rethink everything they were taught about ...
In Part 2, Mr. Kornblum will again use segments from the movies to teach pre-trial and trial tactics...
This CLE course will provide critical insight to counsel for insurers facing bad faith claims on how...
When the investigation concludes, the discipline is issued, and the file is closed, most organizatio...
Estate planning for LGBTQ+ clients and families formed through assisted reproductive technology requ...
Class action litigation continues to evolve rapidly in response to an innovative plaintiffs’ b...