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U.S. Supreme Court Upholds Mandatory Repatriation Tax

21 June 2024

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Approved Changes

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United States

On 20 June 2024, the U.S. Supreme Court issued its opinion in the case Moore v. United States, which concerns the one-time mandatory repatriation tax that was introduced as part of the 2017 Tax Cut and Jobs Act. As previously reported, the repatriation tax required U.S. taxpayers that owned shares in foreign corporations to pay a one-time tax on their share of the corporation's earnings, even if those earnings were reinvested in the corporation and the taxpayers did not receive them. In Moore v. United States, a Washington state couple, Charles and Kathleen Moore, challenged the tax on constitutional grounds....