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Internal Revenue Code (IRC) Constitutional Challenges

Goodwin

Recent Changes and Future Directions: Tax-Exempt Organizations Under the New Administration

Goodwin on

Executive orders, federal funding cuts, and suspended processing of tax-exempt status applications are among the changes affecting nonprofits. ...more

Miller Canfield

Is the Chief of IRS Appeals Constitutionally Appointed?

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The United States Tax Court skillfully dodged answering the headline question with a holding on standing. The court decided, however, that IRS appeals officers and IRS appeals team managers are not officers of the United...more

Latham & Watkins LLP

The Corporate AMT’s Crypto Problem Poses Constitutional Hazards

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Under recent accounting rule changes, unrealized crypto gains must generally be reported on income statements, but questions arise about the alignment of the new Corporate Alternative Minimum Tax with constitutional tax...more

Dorsey & Whitney LLP

The Supreme Court Update - January 13, 2025

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On January 10, 2025, the Supreme Court of the United States granted certiorari in three cases: Becerra v. Braidwood Management, Inc., No. 24-316: This case addresses the constitutionality of the U.S. Preventive Services...more

Katten Muchin Rosenman LLP

IRS Broker Rule for Digital Assets Faces Constitutional Challenge From Industry Leaders

Three digital asset organizations have jointly filed a lawsuit challenging the Internal Revenue Service’s (IRS) new digital asset broker reporting rule. The complaint, filed in the Northern District of Texas on December 27,...more

Cadwalader, Wickersham & Taft LLP

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

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

Perkins Coie

Supreme Court Upholds Mandatory Repatriation Tax as Constitutional

Perkins Coie on

The U.S. Supreme Court held the Mandatory Repatriation Tax (MRT) constitutional in Moore v. United States, No. 22-800, 602 U.S. _, decided June 20, 2024. The MRT requires some American shareholders of American-controlled...more

BakerHostetler

[Podcast] Implications of Supreme Court’s Tax Decision in Moore v. United States

BakerHostetler on

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

Eversheds Sutherland (US) LLP

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

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

McDermott Will & Emery on

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

Cadwalader, Wickersham & Taft LLP

Eager for Moore?

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

Proskauer - Proskauer For Good

Proskauer Files Amicus Brief Before the U.S. Supreme Court on Behalf of the American College of Tax Counsel

On October 23, 2023, Proskauer attorneys submitted an amicus brief in connection with the U.S. Supreme Court case of Moore v. United States[1] on behalf of the American College of Tax Counsel—a nonprofit professional...more

Miller Canfield

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

Miller Canfield on

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

Cadwalader, Wickersham & Taft LLP

Is There Taxation Without Realization? Moore May Create More Questions Than Answers

The U.S. tax system developed in response to colonial opposition to taxation without representation.  As such, Article I of the Constitution provides that Congress may not impose a “direct tax” unless the tax is “apportioned”...more

Bilzin Sumberg

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

Bilzin Sumberg on

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

McDermott Will & Emery

US Treasury Issues Guidance on the ARPA Claw-Back Provision

McDermott Will & Emery on

Earlier this week, the US Department of the Treasury (Treasury) issued formal guidance regarding the administration of the American Rescue Plan Act of 2021 (ARPA) claw-back provision. The guidance (Interim Final Rule)...more

Genova Burns LLC

The Biden Administration’s Health Insurance Priorities

Genova Burns LLC on

The Biden Administration wasted no time in implementing some of the new President’s campaign promises relating to health insurance and the Affordable Care Act (“ACA”). First, on February 10 the Department of Justice filed a...more

WilmerHale

A Constitutional Analysis of the Affordable Housing Credit Improvement Act of 2019

WilmerHale on

This article considers the constitutionality of certain provisions of proposed legislation, the Affordable Housing Credit Improvement Act of 2019. One provision of the bill - apparently offered in legislative response to a...more

Burr & Forman

Cannabis Business Takes Position That § 280E Is Unconstitutional – And It’s Like a Grocery Store For Adults

Burr & Forman on

Cannabis (or marijuana) dispensaries have long stated that they are subjected to harsher tax consequences under the Internal Revenue Code (“IRC” or “Code”) than their “legal” counterparts. Specifically, they have argued, in...more

Lowndes

Tax Court Upholds Constitutionality of Rule Prohibiting Deductions for Marijuana Businesses

Lowndes on

I recently wrote about the Tax Court decision in Northern California Small Business Assistants Inc. v. Commissioner, which addressed whether Section 280E’s denial of tax deductions to marijuana businesses violates the Eighth...more

Eversheds Sutherland (US) LLP

Texas v. United States decision could impact employer-sponsored health plans

On December 14, 2018, a Texas District Court ruled that the Affordable Care Act’s (ACA) requirement that certain individuals maintain a minimum level of health coverage, often referred to as the “Individual Mandate,” is...more

Epstein Becker & Green

Is the Affordable Care Act a House of Cards? If Yes, What Does the Recent Texas Court Decision Mean for the US Health Insurance...

Epstein Becker & Green on

In an unexpectedly broad ruling issued December 14, 2018, the U.S. District Court for the Northern District of Texas declared the Affordable Care Act (“ACA”) as unconstitutional in its entirety. This decision, if ultimately...more

Dorsey & Whitney LLP

U.S. Supreme Court Hands Down Two Significant Tax Decisions

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Yesterday, the Supreme Court handed down two tax decisions, one of which is set to immediately impact internet and other remote retailers nationwide. In South Dakota v. Wayfair, No. 17-494 , the Court overruled Quill Corp. v....more

Eversheds Sutherland (US) LLP

Georgia Legislature enacts significant income, sales, and property tax legislation

The Georgia legislative session concluded on March 29, 2018. In addition to two major bills relating to federal tax reform, Georgia enacted several other pieces of notable tax legislation....more

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