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
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
The Moore v. United States case involves the question of “unrealized income” and its taxation. The plaintiffs, Charles and Kathleen Moore, are challenging the constitutionality of the Section 965 transition tax. The Supreme Court is expected to release an opinion soon, which could have significant impacts on tax policy, potentially reducing federal tax revenues. The ruling may also affect the implementation of the global minimum tax agreement known as Pillar Two. Additionally, the case could lead to changes in the timing of taxes and even preemptively strike down some wealth tax proposals.