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?
Session 8 of 10 - Mr. Kornblum, a highly experienced trial and litigation lawyer for over 50 years, ...
This program will cover how to prepare an effective letter tendering defense and indemnity of an add...
This program provides practical guidance for trial attorneys on how artificial intelligence can be l...
Neither attorneys nor their clients can operate in today's world without understanding Artificial In...
Session 1 of 10 - Session 1 of 10 - Mr. Kornblum, a highly experienced trial and litigation law...
This session provides a practical overview of bank fraud, helping participants identify common fraud...
Financial crimes continue to proliferate, on a global basis. Criminals need to find ways to “l...
Nowhere is the gap between technology and regulation more pronounced than in AI. For lawyers, this o...
This 1-hour program provides a comprehensive exploration of the ethical and compliance challenges in...
Session 5 of 10 - Mr. Kornblum, a highly experienced trial and litigation lawyer for over 50 years, ...