Tax Notes Talk
Less Is Moore: The Supreme Court's Ruling in Moore v. United States
Jun 28, 2024
Tax Notes managing legal reporter Andrew Velarde discusses the Supreme Court's decision in Moore v. United States, highlighting the constitutionality of the transition tax and its implications for future tax laws. The podcast explores the court's comparison of tax provisions, potential loss of tax revenue, and significance for income realization requirements and tax reforms.
13:34
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Quick takeaways
- The Supreme Court upheld the transition tax as an income tax to maintain taxation principles.
- Comparing the transition tax to other tax provisions, the ruling signaled caution against challenging traditional taxation methods.
Deep dives
Supreme Court Rules in Favor of Government on the Transition Tax Issue
The Supreme Court issued a decision in the Moore vs. U.S. case regarding the constitutionality of the section 965 transition tax. The court upheld the Ninth Circuit decision and affirmed that the transition tax is a tax on income, not property, levied on realized income. This ruling maintained longstanding taxation principles and avoided the need to address the realization requirement for income.
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