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?
This program provides immigration attorneys with an in-depth understanding of competency issues in r...
This program provides immigration attorneys with a structured and strategic approach to developing e...
The General Data Protection Regulation (GDPR) continues to impact legal firms and organizations worl...
AI, an innovative technology that was once a supporting act for digital transformation, business str...
Prior to the Supreme Court’s 2023 affirmative action decision, some predicted that this ruling...
This interactive course is designed to equip legal professionals with the knowledge, tools, and stra...
This program provides attorneys with a practical and ethical framework for understanding and respons...
Disasters, whether natural or manmade, happen. Disasters can impact the practice of law and, among o...
Aligning Your Legal Career with Your Values, explores the profound impact of values alignment on ind...
This program introduces psychosocial evaluations as a valuable tool in civil litigation, particularl...