The United States Supreme Court has recently made the decision to grant certiorari in the case, Moore v. United States. This hearsay will provide a review of the judgment made by the Ninth Circuit Court of Appeals on the application of the “transition tax”, instated under Section 965. The transition tax originated as part of the Tax Cuts and Jobs Act of 2017. This legal review is set to shed a critical light on the nuances of the tax legislation’s enactment and the implicated legal jurisdictions.
The “transition tax” is merely one fraction of the comprehensive tax reform that the Tax Cuts and Jobs Act was destined to implement. Conceived by lawmakers as one-time levy on earnings accumulated by foreign corporations under US ownership, the transition tax was seen as a mechanism to stimulate domestic economic growth.
As stated by attorneys at Alston & Bird, more details pertaining to this case have been outlined in a comprehensive Advisory. While it is yet to be determined how the transition tax imposition, as described within the Tax Cuts and Jobs Act of 2017, will cascade down to affect corporations, it certainly marks a progressive stride in the U.S. legal landscape with regards to their tax code – a factor that corporations and law firms alike will be watching with vested interest.