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U.S. Supreme Court to Hear Case on Repatriation Tax

October 19, 2023

U.S. Supreme Court to Hear Foreign Earnings Tax Case
The U.S. Supreme Court is set to hear oral arguments in a case on foreign earnings on Dec. 5. In Moore v. United States, taxpayers are challenging the “mandatory repatriation tax” – also called a transition tax, enacted in the Tax Cuts and Jobs Act – seeking a refund. The taxpayers argue the tax is an unconstitutional charge on unrepatriated foreign earnings.


Microsoft Receives Demand From IRS About Back Taxes
Microsoft received notices from the IRS seeking additional payment of $28.9 billion in penalties and interest for the tax years 2004 through 2013. The company will appeal the IRS’s claims. Microsoft and the IRS disagree on how the company priced its transactions; the claims stem from an audit the IRS conducted from 2004 through 2013. Microsoft denies owing the taxes and stated that certain taxes the company paid as part of the Tax Cuts and Jobs Act could decrease the final tax owed under the audit by up to $10 billion.


Coinbase Pushes Back on Broker Reporting Rules
Cryptocurrency exchange Coinbase opposed broker reporting rules recently proposed by the U.S. Department of the Treasury. Coinbase, in a comment letter, said the proposed regulations may lead to privacy violations and a disproportionate reporting burden on crypto brokers. The letter argues the amount of information crypto exchanges would have to send could overwhelm the IRS’s processing system.

Information contained in this publication should not be construed as legal advice or opinion or as a substitute for the advice of counsel. The articles by these authors may have first appeared in other publications. The content provided is for educational and informational purposes for the use of clients and others who may be interested in the subject matter. We recommend that readers seek specific advice from counsel about particular matters of interest.

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