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 attorneys with a foundational understanding of derivatives and their role in m...
This CLE course will provide critical insight to counsel for insurers facing bad faith claims on how...
During this course, we will go over your rights under the Freedom of Information Act (FOIA) and Priv...
For at least the last half-century, the success or failure of most litigations is determined by how ...
This one-hour CLE program examines the impact of implicit and systemic bias within the legal profess...
This dynamic CLE presentation challenges trial lawyers to rethink everything they were taught about ...
Discussion of religion and reasonable accommodation in the workplace. Thanks to the United States Su...
Lawyers regularly communicate with clients who are angry, overwhelmed, frightened, unrealistic, or d...
As the largest purchaser of goods and services in the world, the United States Government requires f...
This program is geared towards lawyers, experts, commercial property owners, and others in the envir...