Moore v. United States

Summary

The Court held that the 2017 Mandatory Repatriation Tax, which attributes the undistributed income of an American‑controlled foreign corporation to its U.S. shareholders and taxes those shareholders, is a constitutional income tax within Congress’s power and does not require apportionment. The decision rests on a line of precedent allowing Congress to tax either an entity or its owners on undistributed income.