News & Analysis as of October 31, 2024

Apportionment

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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 -

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

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

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

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Supreme Court of the United States › Corporate Taxes › Apportionment

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

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

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

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