United States sixteenth amendmentrealizationdirect tax apportionment

Moore v United States

602 U.S. 572 (2024)

JurisdictionUnited States

CourtSupreme Court of the United States

Year2024

StatusBinding authority

Key Principle

The Sixteenth Amendment permits Congress to attribute a foreign corporation's realized but undistributed income to its U.S. shareholders and tax them on it, so the one-time Mandatory Repatriation Tax (26 U.S.C. s 965) is a constitutional tax on realized income rather than an unapportioned direct tax on unrealized gains.

Area of Law

tax

Related Cases

Connelly v United States 602 U.S. 257 (2024)

Commissioner v Banks 543 US 426 (2005)

Gregory v Helvering 293 US 465 (1935)

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