In the Headlines
December 8, 2023

Narrow Ruling Expected in Justices' Repatriation Tax Review


Tax attorney Joshua Odintz was quoted in a Law360 article about the expectations for a narrow ruling on the constitutionality of the one-time repatriation tax under Section 965 of the Internal Revenue Code after the U.S. Supreme Court justices expressed concerns about the potential case's broader implications. The case Charles G. Moore et al. v. U.S. involved a challenge to the tax code's provision that imposed a one-time tax on offshore income deemed repatriated under the Tax Cuts and Jobs Act. Mr. Odintz noted that the justices seemed reluctant to disrupt the existing tax code and may aim for a judgment that avoids jeopardizing other provisions of current law.

"Subpart F does tax certain types of active income like foreign base company sales and services income; it's just that they're treated as passive for the way of how it's taxed," he said.

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