Wall Street Journal Quotes David Rosenbloom on Moore v. United States

A case that could punch holes in the federal tax code heads to the Supreme Court on Tuesday. 

The court will hear arguments in Moore v. U.S., which challenges a piece of the 2017 tax law that imposed a one-time levy on profits that companies had accumulated outside the U.S. But its implications could reach much further, providing the justices an opportunity to define what Congress can tax under the Constitution—and what it can’t. 

. . .

If the Moores win, investors and companies could demand billions of dollars in refunds tied to the 2017 law. And a loss for the government could prompt a wave of lawsuits over other tax-code provisions, according to lawyers.

“It’s hard to see how this is going to turn out well,” said David Rosenbloom, a tax lawyer at Caplin & Drysdale. “They really are opening up a can of worms.”

. . .

Rosenbloom, the tax lawyer, said he expects the justices to overrule lower courts, perhaps in a narrower way that will nonetheless spur new challenges to tax-code provisions. 

“This is the beginning of the story, not the end. And it could be a long story,” he said. “The court will be writing on a very, very blank slate.”

For the full article, please visit The Wall Street Journal’s website.