Moore v. United States

Summary

The Supreme Court upheld the Mandatory Repatriation Tax, holding that Congress may attribute the realized and undistributed income of an American‑controlled foreign corporation to its U.S. shareholders and tax those shareholders without apportionment. The decision relied on a line of precedents allowing attribution of undistributed income to owners and rejected the petitioners' arguments that the tax is an unapportioned direct tax or violates due‑process.