Charles G. Moore, et al., Petitioners v. United States

  1. January 01, 2024

    Federal Tax Cases To Watch In 2024

    The fates of unrealized income under the U.S. Constitution and the Internal Revenue Service's rulemaking authority under Chevron deference are hot-button tax topics in cases pending before the U.S. Supreme Court. Here, Law360 runs down some of the top federal cases tax experts will be keeping a close eye on in 2024.

  2. December 05, 2023

    Justices Wary Of Repatriation Tax Review Consequences

    U.S. Supreme Court justices questioned a Washington couple's counsel about their challenge to the one-time repatriation tax during oral arguments Tuesday, with some suggesting that a ruling in the couple's favor would upend other parts of the federal tax code.

  3. December 01, 2023

    Up Next At High Court: Purdue Pharma, Taxes & Job Transfers

    The U.S. Supreme Court returns Monday for the last argument session of the calendar year to consider whether bankruptcy courts have the authority to sign off on third-party liability releases in Chapter 11 plans, whether Congress can tax unrealized foreign gains, and which standard should be used to determine the viability of employment discrimination claims.

  4. November 15, 2023

    Repatriation Tax Violates 16th Amendment, Justices Told

    The U.S. Supreme Court should conclude that a one-time mandatory repatriation tax enacted under the 2017 Tax Cuts and Jobs Act is unconstitutional, a couple said Wednesday, urging the justices to reject the federal government's claims that the 16th Amendment allows a levy on unrealized gains.

  5. October 23, 2023

    Repatriation Tax Required For Reform, States Tell Justices

    Sixteen states and Washington, D.C., told the U.S. Supreme Court on Monday that the one-time mandatory repatriation tax passed in the 2017 Tax Cuts and Jobs Act was a necessary provision for the law's international tax overhaul and should be found constitutional.

  6. October 16, 2023

    Repatriation Tax Constitutional, Gov't Tells Justices

    The one-time mandatory repatriation tax passed in the 2017 Tax Cuts and Jobs Act should be found constitutional, the government told the U.S. Supreme Court on Monday, arguing that the 16th Amendment permits taxes on undistributed earnings.

  7. October 12, 2023

    Justices To Hear Repatriation Tax Case In December

    The U.S. Supreme Court will hear oral arguments Dec. 5 in a case testing the constitutionality of the one-time repatriation tax enacted under the 2017 Tax Cuts and Jobs Act, the high court said Thursday.

  8. September 08, 2023

    Justice Alito Refuses To Recuse Himself From Tax Case

    U.S. Supreme Court Justice Samuel A. Alito Jr. has rejected calls to recuse himself from a case the high court is slated to hear this term over a tax on unrealized foreign gains, arguing in a Friday order there is no valid reason for him to step back even though an attorney in the case interviewed him for two Wall Street Journal articles.

  9. July 13, 2023

    Justices' Repatriation Tax Review Could Destabilize US Code

    The U.S. Supreme Court's decision to review the constitutionality of the one-time repatriation tax passed under the 2017 Tax Cuts and Jobs Act could unsettle other tax laws and hurt the prospects of wealth taxes.

  10. July 06, 2023

    Federal Tax Cases To Watch In 2nd Half Of 2023

    In the second half of 2023, tax pros will be watching a U.S. Supreme Court challenge to the repatriation tax enacted in the 2017 federal tax overhaul and a dispute between the government and multinational telecommunications company Liberty Global Inc. in a Colorado federal court. Here, Law360 highlights those and other notable pending federal tax cases to watch for the rest of the year.