On June 20, 2024, the Supreme Court of the United States issued a 7-2 opinion in Moore v. United States, 602 U.S. __ (2024), ruling in favor of the Internal Revenue Service (IRS)....more
The Pennsylvania Department of Revenue (the Department) published an Information Notice setting forth its position as to how the repatriation income and deduction under Section 965 of the Internal Revenue Code (the Code) (the...more
This document discusses Notice 2018-26, the third IRS Notice providing guidance on the new mandatory repatriation tax under ยง 965. Most importantly, the Notice sets forth extensive anti-avoidance rules in respect of...more