Several provisions in the US tax code are at risk of constitutional challenges if the Supreme Court strikes down a levy on unrealized foreign earnings, according to a Joint Committee on Taxation memo.
Taxes on corporations’ foreign income such as Subpart F and the tax on global intangible low-taxed income, known as GILTI, would be vulnerable to legal challenge depending on how justices rule in Moore v. US, the nonpartisan tax scorekeeper wrote in a Tuesday memo to House Ways and Means Ranking Member
Justices will hear the case, brought by ...