Supreme Court Round-Up

July 17, 2024  |  New York Law Journal

Although the Supreme Court’s recently concluded term will be best remembered for its decision in Trump v. United States, the Court also addressed issues of significance to taxpayers and practitioners alike.  In Moore v. United States, the Court issued a much-anticipated decision upholding a provision of the 2017 Tax Cuts and Jobs Act that taxed shareholders for their share of undistributed income generated by controlled foreign corporations.  Connelly v. United States was a less controversial decision addressing the valuation of closely held corporations for estate tax purposes.  While not a tax case, the Court’s decision in Loper Bright Enterprises et al. v. Raimondo, which overruled the Chevron deference doctrine, could turn out to have the most significant impact on tax controversies for years to come by offering new avenues for tax practitioners to challenge the IRS’s interpretation of the Internal Revenue Code.  In his latest article for the NYLJ, “Supreme Court Round-Up,” Morvillo Abramowitz partner Jeremy H. Temkin discusses the Court’s decisions in Moore, Connelly, and Loper Bright.  

Supreme Court Round-Up (pdf | 125.59 KB)