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Tax Liability Tax Cuts and Jobs Act Transition Tax

BakerHostetler

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

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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

Eversheds Sutherland (US) LLP

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

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

Cadwalader, Wickersham & Taft LLP

Eager for Moore?

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

Foodman CPAs & Advisors

Are there conflicting signals from IRS as it relates to Section 965?

IRC Section 965 (Treatment of Deferred Foreign Income Upon Transition to Participation Exemption System of Taxation) was part of the TCJA enacted on December 22, 2017.  ...more

Holland & Knight LLP

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

• 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

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