Taxpayers, including some of the firm’s current and former clients, may be affected by the outcome of the Supreme Court case Moore v. United States, which will address the constitutionality of the Section 965 “Transition Tax,” enacted as part of the Tax Cuts and Jobs Act in 2017. The petitioners in Moore are individual shareholders of an Indian company who had not received distributions from the company during the period of their investment, but who paid the Transition Tax on their proportionate share of the company’s reinvested earnings. The petitioners sued for a refund, arguing that the Transition Tax is unconstitutional. The U.S. Court of Appeals for the Ninth Circuit affirmed the lower court opinion that ruled against the taxpayers, but the Supreme Court agreed to hear the case.