On July 1, 2024, the Supreme Court concluded its October 2023 Term. While the term will probably be best known for the presidential immunity decision in Trump v. United States, the court decided two cases (Moore v. United States and Connelly v. United States) addressing tax issues, and one non-tax case that will reduce the deference courts give the Internal Revenue Service’s statutory interpretations and therefore will impact tax controversies for years to come.

‘Moore v. United States’, No. 22-800 (June 20, 2024)

As part of the Tax Cuts and Jobs Act of 2017, Congress imposed a one-time mandatory repatriation tax (MRT) on the accumulated profits in foreign corporations controlled by Americans. 26 U.S.C. §965.