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?
Most legal professionals are operating in survival mode whether they realize it or not. Not crisis-l...
The Federal Tort Claims Act is the way that the federal government is sued for negligence. There are...
This program provides a comprehensive framework for integrating Borderline Personality Disorder (BPD...
My contract was terminated and the contracting officer did not pay my invoices – what can I do...
Many law firms now rely on AI?driven research, drafting, and workflow tools without fully understand...
The Protections and Limits of the First Amendment when it comes to Expressive Conduct. This PowerPoi...
This program introduces psychosocial evaluations as a valuable tool in civil litigation, particularl...
Explore the transformative potential of generative AI in modern litigation. “Generative AI for...
Learn about the best strategies and tactics to file bid protests at the agency level, U.S. Governmen...
This program provides attorneys with a comprehensive framework for incorporating psychosocial evalua...