News & Analysis as of October 31, 2024

Supreme Court of the United States › Corporate Taxes

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The United States Supreme Court is the highest court of the United States and is charged with interpreting federal law, including the United States Constitution. The Court's docket is largely discretionary with only a limited number of cases granted review each term. The Court is comprised of one chief justice and eight associate justices, who are nominated by the President and confirmed by the Senate to hold lifetime positions. less -

How Did Moore v. United States Change U.S. Tax Law?

Allen Barron, Inc. on 7/31/2024

We have been waiting several months for the Supreme Court of the United States (SCOTUS) to render a decision in Moore v. United States. Initially, our questions focused on the issue of “realized or unrealized income” and...more

Supreme Court Upholds Section 965 Mandatory Repatriation Tax

Freeman Law on 7/1/2024

On June 20, 2024, the U.S. Supreme Court issued its long-anticipated decision in Moore v. United States, in which a 7-2 majority upheld the constitutionality of the mandatory repatriation tax (“MRT”) under section 965 of the...more

SCOTUS Upholds MFT: Moore Et Ux v. US

Gray Reed on 6/25/2024

On June 20, 2024, the Supreme Court released its opinion in Moore et ux v. US, authored by Kavanaugh, decided by 6-3 vote and marking a rare instance for the Court to interpret the 16th Amendment, upholding the...more

Client Advisory: Repatriation Tax on Shareholders | Moore v. U.S.

Burns & Levinson LLP on 6/25/2024

The Tax Cuts and Jobs Act of 2017 amended the law to introduce a new, one-time, mandatory repatriation tax on trillions of dollars of accumulations held abroad by American-controlled foreign entities. The tax is imposed on...more

The Supreme Court Update - June 20, 2024

Dorsey & Whitney LLP on 6/21/2024

The Supreme Court of the United States issued four decisions today: Moore v. United States, No. 22-800: This case concerns the constitutionality of the Mandatory Repatriation Tax (“MRT”) included in the 2017 Tax Cuts and...more

Supreme Court Upholds Mandatory Repatriation Tax but Suggests Wealth Taxes a Step Too Far

BakerHostetler on 6/21/2024

The U.S. Supreme Court today upheld the constitutionality of the so-called “mandatory repatriation tax” in a narrow ruling, stating that the MRT taxes realized income — income earned by the offshore corporation — and...more

Could an Upcoming Supreme Court Case Significantly Change US Tax Law?

Allen Barron, Inc. on 11/29/2023

Could a Supreme Court of the United States (SCOTUS) case significantly change US tax law? We are closely watching the developments in Moore v United States as it carries significant issues regarding “realized” versus...more

Five things to know about the Supreme Court’s grant of certiorari in Moore v. United States

Eversheds Sutherland (US) LLP on 6/28/2023

The Supreme Court granted certiorari on June 26 with respect to the Ninth Circuit’s decision in Moore v. United States. The question presented is whether the section 965 transition tax is a “direct tax” that violates the...more

Taxation & Representation, April 26, 2022

Brownstein Hyatt Farber Schreck on 4/28/2022

SCOTUS Denies New York v. Yellen. The U.S. Supreme Court announced on Tax Day it would not hear a constitutional challenge to the $10,000 deduction limit on state and local taxes (SALT) enacted under the Tax Cuts and Jobs Act...more

Financial Daily Dose 4.6.2021 | Top Story: Treasury Sec. Yellen Proposes Global Minimum Tax Rate for Multinational Businesses

Robins Kaplan LLP on 4/6/2021

Back at it. Let’s get caught up . . . Treasury Secretary Janet Yellen is calling for a global minimum tax rate on multinational corporations, a move aimed at helping “prevent companies based in other countries from having a...more

Skadden's 2020 Insights

Skadden, Arps, Slate, Meagher & Flom LLP on 1/30/2020

Despite political and economic uncertainties, markets and deal activity were resilient in 2019, and strong fundamentals remain in place heading into 2020. Companies continue to face a challenging litigation and enforcement...more

Your Daily Dose of Financial News

Robins Kaplan LLP on 6/12/2018

Germany’s diesel emissions scandal bears a lot of resemblances to the Wells Fargo debacle here at home. It just can’t seem to quit itself. This week, we’ve learned that German authorities have opened a criminal inquiry into...more

Southeast State & Local Tax: Important Developments - March 2016

Williams Mullen on 3/18/2016

The Williams Mullen Southeast State and Local Tax (SESALT) team is pleased to provide you with a comprehensive recap of important tax developments around the Southeast....more

Wynne’s First Casualty: First Marblehead Corp. v. Commissioner

Eversheds Sutherland (US) LLP on 10/14/2015

Today, the U.S. Supreme Court vacated the decision of the Massachusetts Supreme Judicial Court (SJC) in First Marblehead Corp. v. Commissioner of Revenue (First Marblehead) and remanded the case back to the court for...more

Under the Dome: Inside the Maine State House

Pierce Atwood LLP on 6/26/2015

Under the Dome: Inside the Maine State House provides a high-level overview of recent activity at the Maine State House. Legislature Plans Long Day - Early this past Wednesday morning, the Maine House and Senate...more

U.S. Supreme Court Holds Maryland Personal Income Tax Unconstitutional Under Commerce Clause

Cozen O'Connor on 6/4/2015

In Comptroller of the Treasury of Maryland v. Wynne, Dkt. No. 13-485 (U.S. May 18, 2015), the U.S. Supreme Court found that Maryland’s system of personal income taxation violated the nondiscrimination prong of the dormant...more

Wynne Is a Win for Corporate Taxpayers

Faegre Drinker Biddle & Reath LLP on 6/3/2015

On May 18, 2015, the U.S. Supreme Court decided Comptroller of the Treasury of Maryland v. Wynne, No. 13-485, holding that the absence of a credit against the local portion of the state’s personal income tax scheme was an...more

Supreme Court Decides Alabama Department of Revenue v. CSX Transportation, Inc.

Faegre Drinker Biddle & Reath LLP on 3/5/2015

On March 4, 2015, the Supreme Court decided Alabama Department of Revenue v. CSX Transportation, Inc., No. 13-553, holding that a rail carrier can prove discrimination under the Railroad Revitalization and Regulation Reform...more

U.S. Supreme Court Hears Arguments in 4-R Act Case (For the Second Time)

Eversheds Sutherland (US) LLP on 12/12/2014

On December 9, the U.S. Supreme Court heard oral arguments in the last of three state and local tax cases that it accepted this term – Alabama Department of Revenue v. CSX Transportation, Inc. (CSX II), a case that had...more

Supreme Court Decides United States v. Clarke

Faegre Drinker Biddle & Reath LLP on 6/20/2014

On June 19, 2014, the United States Supreme Court held that a taxpayer has the right to examine Internal Revenue Service (IRS) officials regarding their reasons for issuing a summons only if the taxpayer points to facts or...more

Brindisi Tax Academy -- 2013 Year-End Tax Update

Cozen O'Connor on 1/7/2014

I. A Look Back At 2013 Tax Matters, “Gangnam Style” - A. Some Random Observations. - 1. When we penned last year’s Update for you, dear reader, this fair country of ours stood six feet from the edge of the “...more

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Supreme Court of the United States › Corporate Taxes

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