Moore v. United States

144 S. Ct. 1680 (2024)

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Moore v. United States

United States Supreme Court
144 S. Ct. 1680 (2024)

SC

Facts

The 2017 Tax Cuts and Jobs Act (the act) imposed a one-time Mandatory Repatriation Tax (MRT) on Americans with stocks in foreign corporations. The MRT was a pass-through tax that sought to get at trillions of dollars that foreign corporations had accumulated but not distributed to stockholders. Charles and Kathleen Moore (plaintiffs) owned stock in KisanKraft, an American-owned foreign corporation. KisanKraft had a significant amount of accumulated income that it had not distributed to stockholders like the Moores. The act taxed the Moores for their share of this income. The Moores challenged the act in court, arguing that the act was unconstitutional because (1) the income taxed by the MRT was not realized by KisanKraft and (2) even if the underlying taxation was proper, it was a property tax that was unconstitutionally not apportioned according to state population under Article I, Section 9, Clause 4 of the United States Constitution. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Kavanaugh, J.)

Concurrence (Barrett, J.)

Concurrence (Jackson, J.)

Dissent (Thomas, J.)

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