Yesterday, 12:36 PM
It is very much more nuanced than that. The Moore case involves a number of tricky issues, including: whether realization is required for someone to be taxed on income; whether income earned by an entity (e.g., a corporation or partnership) can be attributed and taxed to an owner of the entity; and whether income earned by a foreign corporation over a 30 year period can be taxed to a shareholder; the scope of the Direct Tax Clause; and whether all of the foregoing are limited to foreign corporations or whether they apply to all types of entities and their owners.
I just finished listening to yesterday's oral arguments in the case, and if anyone is interested they can be heard here, although some familiarity with Supreme Court precedent would be helpful: https://www.c-span.org/video/?531893-1/moore-v-united-states-oral-argument
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