Tax Tip #149

Ralph Loggia • August 24, 2023

The Supreme Court Is Taking on a Tax Case—Is this Beneficial to You?

The Supreme Court does NOT take many tax cases. They are taking on one involving the Internal Revenue Code Section 965 Transition Tax from the tax law changes of 2018. This is a tax on untaxed foreign earnings of a foreign corporation as if those earnings had been repatriated to the US.


If an individual paid this tax and if the statue of limitations is still open and if the Supreme Court rules this tax as unconstitutional, then there is an opportunity to receive a refund on the tax paid.

In order to do so, a “Protective Claim” statement needs to be filed.

Think this may apply? Please reach out to a team member who can assist.


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