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June 20, 2024

The latest Tax Alerts and other content of interest

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US Supreme Court upholds validity of IRC Section 965 mandatory repatriation tax
The US Supreme Court held in a 7-2 opinion that Congress may impose a mandatory repatriation tax (MRT) on accumulated and undistributed income of US-controlled foreign corporations under IRC Section 965. In Moore v. United States, No. 22-800 (June 20, 2024), the majority declined to rule whether realization is a constitutional requirement of an income tax, but held that Congress may attribute a business entity’s realized and undistributed income to the shareholders or partners of that entity. In doing so, it emphasized that its holding "applies when Congress treats the entity as a pass-through." A Tax Alert on the Court's opinion is forthcoming.

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