News & Analysis as of November 17, 2024

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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 -

Unanimous Supreme Court Determines Company-Owned Life Insurance Increases Fair Market Value

Husch Blackwell LLP on 8/23/2024

On June 6, 2024, the Supreme Court held 9-to-0 in Connelly v. United States that company-owned life insurance increases the company’s fair market value for estate tax purposes, and the company’s obligation to redeem a...more

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

Holland & Knight LLP on 6/27/2024

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

No Moore Waiting - Supreme Court Upholds Mandatory Repatriation Tax

Williams Mullen on 6/27/2024

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

BEWARE: Redemption Agreement Funded with Corporate-Owned Life Insurance

Rivkin Radler LLP on 6/26/2024

On June 6, 2024, in the case of Connelly v. United States, the United States Supreme Court determined that corporate-owned life insurance proceeds used to redeem a decedent’s shares in the corporation must be included when...more

Supreme Court Rules Against Taxpayers in IRC Section 965 Case

McDermott Will & Emery on 6/24/2024

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

Not the Day We Are Waiting For - SCOTUS Today

Epstein Becker & Green on 6/21/2024

With a significant mass of cases left to decide and only a few weeks to issue the opinions, the U.S. Supreme Court has reduced the backlog by four yesterday. None of them, however, resolves the future of Chevron deference or...more

Supreme Court Rules on Moore v. U.S. – Upholds Mandatory Repatriation Tax

Proskauer - Tax Talks on 6/21/2024

On June 20, 2024, the U.S. Supreme Court ruled 7-2 that the so called mandatory repatriation tax under Internal Revenue Code Section 965 (“MRT”) is constitutional. Justice Kavanaugh wrote the majority opinion...more

US Supreme Court Affirms the Eighth Circuit’s Decision in Favor of the Government Concerning the Estate Tax Treatment of Life...

ArentFox Schiff on 6/18/2024

In Connelly v. US, 602 US ___ (6/6/2024), the US Supreme Court affirmed a decision of the US Court of Appeals for the Eighth Circuit in favor of the government concerning the estate tax treatment of life insurance proceeds...more

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

Rivkin Radler LLP on 10/13/2023

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

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Supreme Court of the United States › Internal Revenue Code (IRC) › Shareholders

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