Tag: mandatory repatriation tax

Should You File a Protective Refund Claim for the Transition Tax While Waiting for the US Supreme Court? Moore Might Mean More! 

Part I of my blog post set out the background and discussed the debate over Internal Revenue Code Section 965  “transition tax” or “mandatory repatriation tax” enacted in 2017. The Supreme Court recently decided to review the 9th Circuit case of Moore v. United States bringing this controversial tax back into the spotlight.  The Court … Continue reading Should You File a Protective Refund Claim for the Transition Tax While Waiting for the US Supreme Court? Moore Might Mean More!  →

Moore Might Mean More! US Supreme Court Review of Moore & Section 965 Transition Tax 

In recent years, one of the most hotly debated tax issues in the United States has been the imposition by Internal Revenue Code Section 965 of the “transition tax” or “mandatory repatriation tax”, a provision of the Tax Cuts and Jobs Act (TCJA) enacted in 2017. The Supreme Court's recent decision to review the 9th … Continue reading Moore Might Mean More! US Supreme Court Review of Moore & Section 965 Transition Tax  →