Is realization a constitutional requirement to have income? This is the question at the center of Moore v. US, a case challenging the constitutionality of a Section 965 international reform transition tax. Wade Sutton walks through the why and next steps of this case, which likely will be heard in fall 2023 and decided in spring 2024. Regardless of the wait-and-watch days ahead, companies are considering protective measures as well as add-on litigation.

IN THIS EPISODE
Wade Sutton, PwC’s National Tax Services International Tax Services Leader
Sindhu Blume, Host, Policy on Demand

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