The Presumption of Innocence Podcast: Episode 68 - The Legacy and Lessons of Guantanamo Bay: A Defense Attorney’s Perspective
Meeting the Moment: How Lawyers Can Unite to Protect Democracy and the Rule of Law - On Record PR
False Claims Act Insights - The Mathematics of Nuclear FCA Verdicts
Podcast - Diamond Alternative Energy, LLC v. EPA: The Intersection of Constitutional and Environmental Law
Solicitors General Insights: The Tale of Two Washingtons — Regulatory Oversight Podcast
The Presumption of Innocence Podcast: Episode 65 -The Power of Interpretation: Constitutional Meaning in the Modern World
The Presumption of Innocence Podcast: Episode 64 - Cages We Built: The Making of Mass Incarceration in America
Solicitors General Insights: The Legal Frontlines in Iowa and Indiana — Regulatory Oversight Podcast
Ampliación del fuero de paternidad
Consumer Finance Monitor Podcast Episode: The Impact of the Election on the FTC
Solicitors General Insights: A Deep Dive With Mississippi and Tennessee Solicitors General — Regulatory Oversight Podcast
Consumer Finance Monitor Podcast Episode: Everything You Want to Know About the CFPB as Things Stand Today, and Lots More - Part 2
Podcast - FTC Commissioner Dismissals: Background and Implications
FCPA Compliance Report: Death of CTA
Consumer Finance Monitor Podcast Episode: Prominent Journalist, David Dayen, Describes his Reporting on the Efforts of Trump 2.0 to Curb CFPB
Consumer Finance Monitor Podcast Episode: Prof. Hal Scott Doubles Down on His Argument That CFPB is Unlawfully Funded Because of Combined Losses at Federal Reserve Banks
The Presumption of Innocence Podcast: Episode 55 - The Power of the Presidential Pardon: Traditions and Turning Points
False Claims Act Insights - Are the FCA’s Qui Tam Provisions Unconstitutional? One Federal Judge Says “Yes"
In That Case: Alexander v. South Carolina State Conference of the NAACP
#WorkforceWednesday® - SpaceX Victory: Court Questions NLRB's Constitutional Authority - Employment Law This Week®
In an opinion issued on May 15, 2025, the State of New York Tax Appeals Tribunal, the highest administrative forum for state tax appeals, upheld the application of the state’s income tax “convenience rule” imposing New York...more
Last week the United States celebrated the 249th anniversary of its declaration of independence from Great Britain. In celebration of the occasion, President Trump signed into law the One Big Beautiful Act which, among other...more
The Trump Administration's renewed focus on tariffs has created novel and interrelated issues for businesses' tax and trade functions. Businesses are now faced with a changing landscape and are exploring strategies to...more
AT A GLANCE - Law 15,042/24 (the “Consumption Tax Reform”) was a milestone for the regulation of Brazil's carbon market. It established the regulated market called the Brazilian Emissions Trading System (SBCE), recognized...more
In the recent United States Tax Court case O’Connor v. Commissioner of Internal Revenue, Judge Arbeit sanctioned the petitioner for advancing frivolous arguments contesting the authority of the IRS to assess tax....more
Under recent accounting rule changes, unrealized crypto gains must generally be reported on income statements, but questions arise about the alignment of the new Corporate Alternative Minimum Tax with constitutional tax...more
In Moore v. United States, the Supreme Court upheld the constitutionality of the mandatory repatriation tax (MRT), saving a significant portion of the current tax code for now. The question in front of the Court was whether...more
A team of BakerHostetler lawyers, led by Partners Andrew Grossman and Jeff Paravano, represented clients Charles and Kathleen Moore at the Supreme Court, arguing that realization is required for federal taxation of income...more
The U.S. Supreme Court on June 20, 2024, ruled 7-2 that Section 965 of the Internal Revenue Code, as revised by the law known as the Tax Cuts and Jobs Act, is constitutional. The issue presented to the Court in Moore v....more
Almost exactly a year after it shook the tax world by granting certiorari, on June 20, 2024, the Supreme Court issued its opinion in Moore v. United States, No. 22-800. By a vote of 7-2, the Court upheld the constitutionality...more
On June 20, 2024, the Supreme Court of the United States issued a 7-2 opinion in Moore v. United States, 602 U.S. __ (2024), ruling in favor of the Internal Revenue Service (IRS)....more
On June 20, 2024, the U.S. Supreme Court decided Moore v. United States, No. 22-800, holding that the Mandatory Repatriation Tax (MRT) — a provision in a 2017 tax reform law — could constitutionally impose a one-time...more
I have reported in several prior blog posts the significant events impacting the newly enacted Washington state capital gains tax. The turbulent ride of this legislation continues!...more
On February 14, 2024, in Schaad v. Alder, the Supreme Court of Ohio upheld the constitutionality of a temporary Ohio law allowing municipalities where a principal place of business was located to collect income tax from...more
On December 5, the Supreme Court heard oral arguments on Moore v. United States, which is potentially the next landmark tax case on the meaning of income under the Sixteenth Amendment....more
Unless you have been living under a rock—as we tax lawyers are wont to do—you have probably been following Moore v. United States, which we last discussed. On December 5, the tax community stepped into the spotlight...more
On October 23, 2023, Proskauer attorneys submitted an amicus brief in connection with the U.S. Supreme Court case of Moore v. United States[1] on behalf of the American College of Tax Counsel—a nonprofit professional...more
In this article, we discuss some basic considerations for preparing a protective refund claim. These considerations are particularly relevant for taxpayers whose statutes of limitations for refund claims are expiring soon and...more
A tax case pending in the United States Supreme Court, Moore v. United States, may cause a cataclysmic change in the federal income tax. The 16th Amendment to the United States Constitution empowers Congress to impose “taxes...more
The U.S. tax system developed in response to colonial opposition to taxation without representation. As such, Article I of the Constitution provides that Congress may not impose a “direct tax” unless the tax is “apportioned”...more
The U.S. Supreme Court (“SCOTUS”) has decided to hear a case (Moore v. U.S., No. 22-800 ) where individual taxpayers owned shares in a controlled foreign corporation (“CFC”) and were subject to the so-called “transition tax”...more
It is a rainy day in the Pacific Northwest with chances of snow showers. For those taxpayers that reside in the state of Washington or own highly appreciated capital assets located in the state, their day just got a bit...more
Effective January 1, 2022, Washington imposes an excise tax on an individual’s long-term capital gains from the sale of stock, bonds, and other assets exceeding $250,000 if the assets were located in Washington at the time of...more
By motion dated November 3, 2022, the Washington State Attorney General asked the Supreme Court of the State of Washington to allow the Washington Department of Revenue to implement and collect the capital gains tax struck...more
The U.S. Supreme Court decision in South Dakota v. Wayfair, Inc. 138 S. Ct. 2080 (2018) upended how businesses think about state tax compliance. In Wayfair, the Court upheld a South Dakota sales tax law that taxed...more