In the Headlines
June 26, 2024

Repatriation Tax Ruling May Sway State Wealth Tax Debates


Tax attorney John Wertz was quoted in a Law360 article discussing how the U.S. Supreme Court's ruling upholding the constitutionality of the federal mandatory repatriation tax (MRT) could impact state wealth tax policy conversations. A couple from Washington state with a stake in the Indian company KisanKraft challenged the MRT, which requires controlled foreign corporation shareholders to pay a one-time transition tax. The couple claims the rule infringes on the Constitution's apportionment clause; however, the Supreme Court asserted the one-time tax on internationally stored deferred foreign earnings is lawful. The ruling raised questions about income realization and due process, which Mr. Wertz said should be part of wealth tax discussions in state governments.

"It's something that the states will have to have on their radar going forward," he explained.

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