000			01708nab a2200217 c 4500
999			_c148403 _d148403
003			ES-MaIEF
005			20231031112744.0
007			ta
008			231030t2023 us ||||| |||| 00| 00eng d
040			_aES-MaIEF _bspa _cES-MaIEF
100	1		_948792 _aJensen, Erik M.
245		0	_aIs realization necessary to have taxable income? _bthe Supreme Court might tell us _c Erik M. Jensen
500			_aResumen.
520			_aThe Supreme Court has granted certiorari in Moore v. United States to consider whether realization is a requirement to have income within the meaning of the Sixteenth Amendment. Both a district court and a panel of the Ninth Circuit had concluded that the Mandatory Repatriation Tax enacted in 2017 was valid even though a married couple was taxed on undistributed earnings of a controlled foreign corporation and the earnings may have been attributable to tax years going back as far as 1987. This article describes the basics of the controversy and considers some of the issues associated with the case, including whether a Court holding that realization is required might call into question the constitutionality of many other Code provisions; whether such a holding would automatically make an unapportioned wealth tax possible; and what effect we should give to the fact that not everyone in 1913, when the amendment was ratified, understood the meaning of income in the same way
650			_aIMPUESTOS _947460
650		4	_aTRABAJADORES DESPLAZADOS _967804
650		4	_aESTADOS UNIDOS _942888
650		4	_aJURISPRUDENCIA _947570
773	0		_9170442 _oOP 235/2023/4 _tJournal of Taxation of Investments _w(IEF)51921 _x 0747-9115 _g v. 40, n. 4, Summer 2023, p. 39-56
942			_cART