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Supreme Court of the United States › Tax Cuts and Jobs Act

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... more +
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 -
Cozen O'Connor

Cozen Currents: Getting Down to Brass Tacks on Tax Reform

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The Cozen Lens - · Tax reform will be the top legislative issue next year regardless of who wins the elections and Congress, not the White House, will be the ones in the driver’s seat. · The Supreme Court begins its...more

Allen Barron, Inc.

Tax and Estate Planning for Small Business Owners and S Corporations with No Employees

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Many small business owners mistakenly believe business succession planning and estate planning is for those with substantial wealth. This is simply a myth which does not reflect the nature of business or home ownership....more

Cozen O'Connor

Cozen Currents: In Trump's Image

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The Cozen Lens- •Even if this year’s Republican Party platform is shorter than usual, former President Trump’s influence is evident in not only the policies it proposes, but perhaps more so in the ones it avoids. •In a...more

Rivkin Radler LLP

The Supreme Court’s Non-Opinion On The “Realization” of Income – A Lost Opportunity?

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In less than four months, the citizens of the United States will be electing their next President to a four-year term. They will also be deciding which of the two major political parties will “control” the Senate, the House,...more

BakerHostetler

[Podcast] Implications of Supreme Court’s Tax Decision in Moore v. United States

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A team of BakerHostetler lawyers, led by Partners Andrew Grossman and Jeff Paravano, represented clients Charles and Kathleen Moore at the Supreme Court, arguing that realization is required for federal taxation of income...more

Holland & Knight LLP

Moore Thoughts: An Incremental Opinion from the U.S. Supreme Court

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The U.S. Supreme Court on June 20, 2024, ruled 7-2 that Section 965 of the Internal Revenue Code, as revised by the law known as the Tax Cuts and Jobs Act, is constitutional. The issue presented to the Court in Moore v....more

Williams Mullen

No Moore Waiting - Supreme Court Upholds Mandatory Repatriation Tax

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On June 20, the U.S. Supreme Court released its opinion in the closely watched case of Moore v. United States. In a 7-2 decision, the court upheld the constitutionality of the mandatory repatriation tax (MRT), also referred...more

Eversheds Sutherland (US) LLP

Doing less with Moore: Supreme Court upholds section 965 transition tax in Moore v. United States

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Almost exactly a year after it shook the tax world by granting certiorari, on June 20, 2024, the Supreme Court issued its opinion in Moore v. United States, No. 22-800. By a vote of 7-2, the Court upheld the constitutionality...more

Burns & Levinson LLP

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

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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

Dorsey & Whitney LLP

The Supreme Court Update - June 20, 2024

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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

BakerHostetler

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

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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

Faegre Drinker Biddle & Reath LLP

Supreme Court Decides Moore v. United States

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On June 20, 2024, the U.S. Supreme Court decided Moore v. United States, No. 22-800, holding that the Mandatory Repatriation Tax (MRT) — a provision in a 2017 tax reform law — could constitutionally impose a one-time...more

Kohrman Jackson & Krantz LLP

Unrealized Income Under Scrutiny: Will SCOTUS Unleash Chaos on the US Tax Code?

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In December 2023, the Supreme Court considered the fundamental question: “How is income defined?” Moore v. United States centered on the question of taxation of unrealized income. Unrealized income is defined as a gain that...more

ArentFox Schiff

Five, Six, Seven, Eight, Nine, Ten . . . Will We Love 2024? Top 10 Tax Issues for the Year

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The 2024 election year promises to make taxes front-of-mind for many business and individual taxpayers. Beyond the election, there are other note-worthy developments, along with several highly anticipated tax law cases that...more

Cadwalader, Wickersham & Taft LLP

Eager for Moore?

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On December 5, the Supreme Court heard oral arguments on Moore v. United States, which is potentially the next landmark tax case on the meaning of income under the Sixteenth Amendment....more

Eversheds Sutherland (US) LLP

Moore questions: Impressions from oral argument

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On December 5, 2023, the US Supreme Court heard oral arguments in Moore v. United States, addressing the constitutionality of the section 965 transition tax, which was enacted in the Tax Cuts and Jobs Act of 2017. Section 965...more

Cadwalader, Wickersham & Taft LLP

Moore Bark Than Bite? Supreme Court Weighs In

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Unless you have been living under a rock—as we tax lawyers are wont to do—you have probably been following Moore v. United States, which we last discussed.  On December 5, the tax community stepped into the spotlight...more

Allen Barron, Inc.

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

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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

Cadwalader, Wickersham & Taft LLP

Joint Committee on Taxation Cautions Less Is Moore

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Earlier in the summer, the Supreme Court announced a new case on its docket for the upcoming term, Moore v. United States, which we discussed here. The case has been set for argument on December 5....more

Rivkin Radler LLP

Supreme Court to Decide: No Realization Means No Moore Income Tax?

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Many of you, perhaps most, may have read about a case that will be heard by the U.S. Supreme Court during its current term. The case, Moore v. United States, comes out of the Ninth Circuit Court of Appeals. The Supreme Court...more

Miller Canfield

Will the Supreme Court Invalidate One or More Sections of the Tax Cuts and Jobs Act?

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A tax case pending in the United States Supreme Court, Moore v. United States, may cause a cataclysmic change in the federal income tax. The 16th Amendment to the United States Constitution empowers Congress to impose “taxes...more

ArentFox Schiff

The US Supreme Court to Rule on the TCJA Transition Tax: Is the Realization Requirement Soon to Be No Moore?

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On June 26, the US Supreme Court agreed to hear the appeal of Moore v. United States, a development that reverberated throughout the world of tax. The Moore case deals with the constitutionality of the transition tax under...more

Eversheds Sutherland (US) LLP

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

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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

Dorsey & Whitney LLP

The Supreme Court Update - June 26, 2023

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The Supreme Court of the United States granted certiorari in two cases: Rudisill v. McDonough, No. 22-888: This case concerns veterans’ entitlement to educational benefits under the Montgomery G.I. Bill and the Post-9/11...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, April 26, 2022

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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

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