We have been waiting several months for the Supreme Court of the United States (SCOTUS) to render a decision in Moore v. United States. Initially, our questions focused on the issue of “realized or unrealized income” and whether income could be taxed before it is “realized.” The Court avoided this issue almost entirely. So, how … Read more
here. Despite the fact that the thermometer still reads summer, fall is creeping closer. According to the National Retail Federation, one in five (22%) back-to-school shoppers have already started gearing up for the 2024-25 school year (you can count me as one of them). However, with above-average prices in stores and online, those shoppers are … Read more
Last summer, I wrote two columns about a peculiar tax case that the Supreme Court decided to hear. Although the amount of tax involved in the case was less than $15,000, ruling in the taxpayer’s favor could have fundamentally gutted the Internal Revenue Code. A major part of the 2017 Tax Cuts and Jobs Act … Read more
“Just the FACTs” is a round-up of news stories and information regarding efforts to combat corrupt financial practices, including offshore tax haven abuses, corporate secrecy, and money laundering through the financial system. Send feedback or items for future newsletters to Thomas Georges at tgeorges@thefactcoalition.org Here is the State of Play FACT Calls on Congress to … Read more
June 20, 2024 Click for PDF Moore v. United States, No. 22-800 – Decided June 20, 2024 Today, in a case widely seen as a test of Congress’s ability to enact wealth taxes, the Supreme Court held narrowly that Congress did not violate the Sixteenth Amendment by requiring U.S. shareholders to pay a one-time tax on … Read more
In Moore v. United States, the U.S. Supreme Court rejected a constitutional challenge to the Mandatory Repatriation Tax (MRT), holding that the MRT does tax income — the realized earnings of foreign corporations — and thus is a constitutionally permissible income tax authorized by the Sixteenth Amendment. The MRT is a “one-time, backward-looking” tax in … Read more
June 20, 2024 June 20, 2024 Today, seven of the nine justices on the U.S. Supreme Court upheld the constitutionality of a tax on offshore corporate profits that was one of the few significant revenue-raisers in the Trump tax law. If the Court had agreed with the plaintiffs in the case — as well as … Read more
The Supreme Court on Thursday rejected a challenge to the constitutionality of taxation on foreign income in a case backed by business and anti-regulatory interests who said the provision was similar to a “wealth tax.” The 7-2 decision by Justice Brett Kavanaugh upheld the mandatory repatriation tax, siding with the Biden administration to uphold the provision of the 2017 … Read more
(June 21): The US Supreme Court upheld a 2017 tax on American-owned businesses’ foreign profits, rejecting an appeal that could have saved companies hundreds of billions of dollars.Voting 7-2, the justices said Congress has the constitutional power to tax people and companies on their share of undistributed corporate income, at least when it comes to … Read more
Key Takeaways The Supreme Court upheld the constitutionality of the so-called mandatory repatriation tax (MRT) in a narrow ruling, stating that the MRT taxes realized income and attributes that corporate income to shareholders. A team of BakerHostetler attorneys, led by Partners Andrew Grossman and Jeffrey Paravano, represented Charles and Kathleen Moore at the U.S. Supreme … Read more