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Constitutional Challenges Internal Revenue Code (IRC) Taxation

Venable LLP

New ERC Cutoff in “One Big Beautiful Bill” Runs into Serious Parliamentary and Constitutional Headwinds

Venable LLP on

The House reconciliation measure branded the “One, Big, Beautiful Bill” (OBBB) would bar the IRS from paying any Employee Retention Credit (ERC) refund claims filed after January 31, 2024. Section 112205 of OBBB also imposes...more

Perkins Coie

Supreme Court Upholds Mandatory Repatriation Tax as Constitutional

Perkins Coie on

The U.S. Supreme Court held the Mandatory Repatriation Tax (MRT) constitutional in Moore v. United States, No. 22-800, 602 U.S. _, decided June 20, 2024. The MRT requires some American shareholders of American-controlled...more

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