News & Analysis as of November 15, 2024

Transition Tax

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Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -

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

BakerHostetler on 7/1/2024

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

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

Eversheds Sutherland (US) LLP on 6/26/2024

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

Eager for Moore?

Cadwalader, Wickersham & Taft LLP on 2/6/2024

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

Is There Taxation Without Realization? Moore May Create More Questions Than Answers

Cadwalader, Wickersham & Taft LLP on 7/28/2023

The U.S. tax system developed in response to colonial opposition to taxation without representation. As such, Article I of the Constitution provides that Congress may not impose a “direct tax” unless the tax is “apportioned”...more

A Transition to What? SCOTUS Set to Decide the Fate of IRC 965

Bilzin Sumberg on 7/20/2023

The U.S. Supreme Court (“SCOTUS”) has decided to hear a case (Moore v. U.S., No. 22-800 ) where individual taxpayers owned shares in a controlled foreign corporation (“CFC”) and were subject to the so-called “transition tax”...more

Weekly IRS Roundup September 27 – October 1, 2021

McDermott Will & Emery on 10/5/2021

Presented below is our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for the week of September 27, 2021 – October 1, 2021... September 28, 2021: The IRS released a revenue...more

IRS “BEEFS UP” Section 965 COMPLIANCE For 2017 And 2018 Returns

Foodman CPAs & Advisors on 11/27/2019

On July 2, 2018, the IRS introduced a Compliance Campaign directed at Section 965 (Transition Tax) of the Internal Revenue Code (IRC). In its original launch, the Section 965 Campaign stated that U.S. shareholder are...more

U.S. Tax Reform: Impacts and Opportunities for Mexican Businesses, Part 1 - A General Overview on Issues That U.S. and Mexican...

Holland & Knight LLP on 7/23/2018

• The Tax Cuts and Jobs Act (Tax Act), signed into law on Dec. 22, 2017, made significant changes to the manner in which U.S. corporate and individual taxpayers are taxed on income from international operations. • The Tax...more

New York State Responds to Federal Tax Reform

Skadden, Arps, Slate, Meagher & Flom LLP on 4/10/2018

On March 30, 2018, the New York Legislature passed the 2018–2019 Budget Bill (SB. 7509-C/A 9509-C) (Budget Bill), which addresses several provisions of the newly enacted Tax Cuts and Jobs Act (P.L. 115-97) (TCJA) and...more

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