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
The Supreme Court held that a company may bring a pre-enforcement challenge under the Administrative Procedure Act ("APA") to an IRS reporting requirement backed by a tax penalty.
On May 17, 2021, the U.S. Supreme Court...more
5/20/2021
/ Administrative Procedure Act ,
Anti-Injunction Act ,
CIC Services LLC v IRS ,
Criminal Liability ,
Criminal Penalties ,
Federal Jurisdiction ,
IRS ,
Notice and Comment ,
SCOTUS ,
Subject Matter Jurisdiction ,
Tax Penalties