On June 20, 2024, the Supreme Court issued a narrow ruling upholding the constitutionality of the transition tax in Moore v. United States. The Court did not address issues related to pass-through taxation, realization events, and a potential future wealth tax. The ruling preserves the tax laws related to foreign corporations that were ushered in via the 2017 Tax Cuts and Jobs Act.
Gray Reed Partner Austin Carlson recently appeared on The Essential Tax Podcast, hosted by Wolf Group Principal and Director of International Tax Mishkin Santa, to share his thoughts and general takeaways on the ruling in the Moore case and discuss the impact of the ruling as it relates to Offshore Voluntary Disclosure Practice. Mishkin and Austin also discussed current issues related to IRS amnesty programs for US individuals that have not properly or fully disclosed foreign financial assets and income and the impending sunset of the 2017 Tax Cuts and Jobs Act at the end of calendar year 2025.
As a business lawyer and CPA, Austin Carlson brings unique skills and perspectives to every area of his practice, which includes corporate and tax counsel on M&A deals, complex corporate and tax planning for domestic and international transactions, and foreign account and income disclosure and penalty abatement issues including the Streamlined Filing Compliance Procedures and Delinquent International Information Return Submission Procedures. He helps companies (domestic and international) and individuals structure corporations, LLCs, partnerships and nonprofit entities achieve their transactional tax and corporate planning goals, and successfully resolve tax controversies with the IRS and state taxing authorities.
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