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More on Moore: Unpacking the Recent Oral Arguments in the Moore Case

12.18.2023 | Duration: 24:41

Inside International Tax podcast: What can be gleaned from the oral arguments before the Supreme Court in Moore v. United States on the constitutionality of the mandatory repatriation tax?

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Podcast overview

On December 5, 2023, the U.S. Supreme Court heard oral arguments in Moore v. United States, which involves the taxpayers’ challenge of the constitutionality of the section 965 mandatory repatriation tax. The question at issue in the case is focused narrowly on section 965, but the outcome has the potential to have far-reaching consequences, depending on how the Supreme Court decides the case.

Why did the Court grant certiorari in this case and are there concerns outside of section 965 that may have motivated it?  How did the taxpayer and the government frame the relevant issue, and how did each Justice respond? What can the discussion between the Justices and counsel tell us about the potential scope of the Court’s holding?

Join us as our podcast co-host Kristen Gamboa is joined by her fellow co-host Gary Scanlon to explore these issues and more on the latest episode of Inside International Tax.

Meet our podcast team

Image of Gary Scanlon
Gary Scanlon
Principal, International Tax, Washington National Tax, KPMG US
Image of Kristen Gamboa
Kristen Gamboa
Managing Director, International Tax, Washington National Tax, KPMG US

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July 27, 2023 | Moore than Words: Supreme Court Grants Cert on Section 965 Challenge

Podcast: What are the potential ramifications from the Supreme Court’s decision to hear the section 965 challenge in Moore? What should taxpayers consider doing now?

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