Amicus Brief Filed in Supreme Court Case Moore v. United States

This Amicus brief was filed September 6, 2023, in the very important Moore case. The brief merits a close reading by everyone. The subject is the validity of the Mandatory Repatriation Tax enacted as part of the Tax Cuts and Jobs Act of 2017, which found its way into Internal Revenue Code section 965. If plaintiffs in the case win, there probably will be huge tax revenue losses for the Government. We predict that Congress will be forced to weigh in again on the subject of taxation of foreign income. This may open the door to residence-based taxation proposals focusing on the taxation of individuals including, importantly, Americans resident overseas. Americans abroad need to prepare now to make their presence and their needs known in a detailed and aggressive way.