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Income Taxes › Supreme Court of the United States › Internal Revenue Service

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Cadwalader, Wickersham & Taft LLP

The Supreme Court Has Saved the Tax Code for Now and Left Room for Moore

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In Moore v. United States, the Supreme Court upheld the constitutionality of the mandatory repatriation tax (MRT), saving a significant portion of the current tax code for now. The question in front of the Court was whether...more

Jones Day

Supreme Court Upholds the Mandatory Repatriation Tax in Moore v. United States

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The U.S. Supreme Court has affirmed the Ninth Circuit's decision in Moore v. United States, upholding the constitutionality of the mandatory repatriation tax enacted in 2017....more

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

Holland & Knight LLP

Moore Thoughts: An Incremental Opinion from the U.S. Supreme Court

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The U.S. Supreme Court on June 20, 2024, ruled 7-2 that Section 965 of the Internal Revenue Code, as revised by the law known as the Tax Cuts and Jobs Act, is constitutional. The issue presented to the Court in Moore v....more

Williams Mullen

No Moore Waiting - Supreme Court Upholds Mandatory Repatriation Tax

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On June 20, the U.S. Supreme Court released its opinion in the closely watched case of Moore v. United States. In a 7-2 decision, the court upheld the constitutionality of the mandatory repatriation tax (MRT), also referred...more

Eversheds Sutherland (US) LLP

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

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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

McDermott Will & Emery

Supreme Court Rules Against Taxpayers in IRC Section 965 Case

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On June 20, 2024, the Supreme Court of the United States issued a 7-2 opinion in Moore v. United States, 602 U.S. __ (2024), ruling in favor of the Internal Revenue Service (IRS)....more

Rivkin Radler LLP

Missing the Tax Court’s 90-Day Deficiency Deadline – Now What?

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Over the years, I have observed there is only one thing that a taxpayer fears more than being notified by the IRS that their income tax return for a particular taxable year has been selected for audit, and that is being...more

Cadwalader, Wickersham & Taft LLP

Eager for Moore?

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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

Miller Canfield

Will the Supreme Court Invalidate One or More Sections of the Tax Cuts and Jobs Act?

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A tax case pending in the United States Supreme Court, Moore v. United States, may cause a cataclysmic change in the federal income tax. The 16th Amendment to the United States Constitution empowers Congress to impose “taxes...more

Bilzin Sumberg

A Transition to What? SCOTUS Set to Decide the Fate of IRC 965

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The U.S. Supreme Court (“SCOTUS”) has decided to hear a case (Moore v. U.S., No. 22-800 ) where individual taxpayers owned shares in a controlled foreign corporation (“CFC”) and were subject to the so-called “transition tax”...more

Kohrman Jackson & Krantz LLP

Move Over TikTok, the Tax Man May Be Snooping on You, Too

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In a rare unanimous opinion, the U.S. Supreme Court recently confirmed that existing law allows the IRS to probe your bank records, without ever notifying you. Under the applicable statute, the Court concluded the IRS is not...more

Rivkin Radler LLP

Supreme Court Upholds IRS Collections Summons Without Notice

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The Supremes- The Constitution has figured prominently in the news of late. In the days preceding the initial discussions among members of the Administration and the Congressional leadership regarding the debt ceiling,...more

Cadwalader, Wickersham & Taft LLP

Supreme Court Hands Taxpayers a Victory in FBAR Penalty Case

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Taxpayers recently won a significant victory at the Supreme Court in a penalty case involving a non-willful failure to file a Report of Foreign Bank and Financial Accounts (“FBAR”) under the Bank Secrecy Act (the “BSA”)....more

Polsinelli

Major Win For Taxpayers: SCOTUS Limits FBAR Penalties to Per Report Not Per Financial Account

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After years of litigation, the United States Supreme Court, in Bittner v. United States, 598 U.S. ____ (2023), determined that the penalty for a non-willful failure to file a Report of Foreign Bank and Financial Accounts...more

White and Williams LLP

Supreme Court Rules For Taxpayers On Non-Willful FBAR Penalties

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Taxpayers who hold foreign accounts finally received clarity as the Supreme Court ruled that the $10,000 non-willful penalty for failure to file a FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR) applies...more

Rosenberg Martin Greenberg LLP

Affordable Care Act Battle Rages On: Fourth Circuit Holds Individual Mandate Is a Tax in Bankruptcy

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As originally enacted, the Affordable Care Act (“ACA”) required most people to maintain health insurance. Those who did not maintain the required insurance were obligated to pay a “shared responsibility payment” (“SRP”),...more

McDermott Will & Emery

Supreme Court Denies Certiorari in Whirlpool

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On November 21, 2022, the Supreme Court of the United States denied certiorari in Whirlpool Financial Corp., et al., Petitioners v. Commissioner of Internal Revenue, No. 22-9. This means that the US Court of Appeals for the...more

Holland & Hart - The Benefits Dial

I Wanna Know What Love Is . . . and When to Provide Domestic Partner Benefits

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When the Supreme Court legalized same-sex marriages back in 2015, the IRS clarified that two people are legally married under federal law when they also are legally married under their state’s law. Because of this...more

Seward & Kissel LLP

July 2022 U.S. Federal Income Tax Updates

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This Memorandum highlights several important U.S. federal income tax developments in the summer of 2022, including: (i) the Supreme Court agreeing to hear an FBAR penalty case, (ii) the Internal Revenue Service (“IRS”)...more

Brownstein Hyatt Farber Schreck

Taxation & Representation, April 26, 2022

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SCOTUS Denies New York v. Yellen. The U.S. Supreme Court announced on Tax Day it would not hear a constitutional challenge to the $10,000 deduction limit on state and local taxes (SALT) enacted under the Tax Cuts and Jobs Act...more

Sheppard Mullin Richter & Hampton LLP

The Expanded Reach of States for Sales & Use Tax Purposes – More Than Just e-Commerce Retailers are Impacted

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All states but one that impose a sales and use tax now have laws requiring out-of-state companies to collect tax if they have a significant economic presence in a state.  The Governor of Missouri, the last remaining state, is...more

Dorsey & Whitney LLP

The Supreme Court - May 17, 2021

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Today, the Supreme Court of the United States issued the following four decisions: BP p.l.c. v. Mayor and City Council of Baltimore, No. 19-1189: Congress has commanded that generally, an order remanding a case back to...more

ArentFox Schiff

Supreme Court to Hear Challenge to Nonprofit Donor Disclosure Case

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Currently, charities are only required to disclose the names of their major donors to the IRS – which must keep them under seal – on federal Schedule B. The Supreme Court is set to schedule arguments in April for two...more

Fenwick & West LLP

Intellectual Property Bulletin - Summer 2018

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In This Issue - US Taxation of IP After Tax Reform - U.S. taxation of intellectual property has become astoundingly more complex after the Tax Cuts and Jobs Act. The new rules are so complex that the IRS and Treasury...more

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