Realization requirement still open question after narrow Moore decision (8:02)

Wade Sutton
Monday, June 24, 2024

While House and Senate members of Congress are looking ahead to the 2025 tax legislative action and expiring TCJA provisions, the US Supreme Court released its decision in Moore v. US upholding the constitutionality of the Section 965 transition tax enacted as part of TCJA. Wade Sutton shares his insights on the narrowness of the decision which left open the question on the realization of income requirement.

Wade Sutton, PwC’s National Tax Services International Tax Services Leader
Andrew Prior, Managing Director, PwC’s Tax Policy Services Practice
Scott McCandless, Host, Policy on Demand

PwC Insight: Supreme Court upholds constitutionality of mandatory repatriation tax in Moore

Upcoming webcasts:

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In case you missed it:

Policy on Demand: Week in Review with Chairman Dave Camp (06/21/24)
Policy on Demand: More clarity, more restrictions in OECD’s latest guidance package (06/20/24)
Policy on Demand: Election Watch (06/19/24)

Happening this week:
June 24 and 25: The OECD US Council for International Business (USCIB) will hold an international tax conference in Washington, DC.
June 26: The House Ways and Means Committee will hold a hearing on child welfare in foster care and the Health Subcommittee will hold a hearing on value-based care.

June 25: Colorado, New York, and Utah will hold elections. Colorado’s 4th Congressional District hold a special general election, 

Geography - USA
Practice Area - NTS - Tax Policy Services


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