Moore than Words: Supreme Court Grants Cert on Section 965 Challenge

Episode 07-2023 | On June 26, 2023, the U.S. Supreme Court granted certiorari in Moore v. United States, which involves the taxpayers’ challenge of the constitutionality of the section 965 mandatory repatriation tax. While the case itself is narrowly focused on section 965, the Court’s decision could have far-reaching consequences on the tax law and, in particular, the U.S. international tax provisions of the Code.

Why did the Supreme Court grant the writ and what does that tell us about their intentions?  What are some of the potential outcomes of the case? What practical steps should taxpayers consider taking to protect their interests in anticipation of the case’s various potential outcomes?  

Join us as our podcast co-hosts Gary Scanlon and Kristen Gamboa are joined by Mary Slonina and Dan Winnick to explore these issues and more on the latest episode of Inside International Tax.