News & Analysis as of November 17, 2024

Supreme Court of the United States › Transition Tax

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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 -

[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

Moore Bark Than Bite? Supreme Court Weighs In

Cadwalader, Wickersham & Taft LLP on 12/22/2023

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

Joint Committee on Taxation Cautions Less Is Moore

Cadwalader, Wickersham & Taft LLP on 11/28/2023

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

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

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

ArentFox Schiff on 7/6/2023

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

Supreme Court Takes Up Constitutional Challenge to Section 965 Transition Tax

McDermott Will & Emery on 7/6/2023

On June 26, 2023, the Supreme Court of the United States agreed to hear a rare challenge under the Sixteenth Amendment and Tax Clauses to Section 965 of the tax code. In Moore v. United States, the justices will consider...more

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Supreme Court of the United States › Transition Tax

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