The U.S. Court of Appeals for the Ninth Circuit issued an opinion (decision) filed on 7 June 2022 that affirms a district court's dismissal of a constitutional challenge to the transition tax on undistributed CFC earnings that was introduced as part of the 2017 Tax Cuts and Jobs Act (TCJA). The opinion summary is as follows: --- SUMMARY Tax The panel affirmed the district court's dismissal of an action seeking to invalidate the Mandatory Repatriation Tax. Taxpayers invested in a controlled foreign corporation (CFC), which is a foreign corporation whose ownership or voting rights are more than 50% owned by...