The Supreme Court has ruled 7 to 2 in favor of the government in Moore v. United States, and we have assembled a panel of experts, including counsel for plaintiffs Charles and Kathleen Moore, the government’s chief litigator in the lower courts, and the author of an amicus brief to discuss their decision. What are the implications of the Court’s decision? What factors helped shape it? How will the decision affect the tax landscape?

The OECD’s pillar 2 will not only shape international and federal taxes but also affect many state and local taxes classified as covered taxes under its framework. That makes state and local taxation a crucial part of its analysis. What choices will states have to make regardless of whether the United States adopts pillar 2? How will they alter their tax structures and policies to align with the global framework? What can they do to ensure their compliance while maintaining their competitiveness? And what lessons can states take from their history of tax competition and cooperation and apply to this new challenge?

As pillar 2 moves to implementation, are developing countries prepared to participate? Have the final rules addressed their concerns? Do tax administrations in these nations still face disadvantages, and do they need additional support? Can the rules be improved to better safeguard developing countries?

The tax community is closely watching Moore v. United States because of its potential to upend large parts of the tax code. What could this case mean for the government’s ability to collect taxes? How likely is the Court to rule for the Moores? And if so, how large are the possible implications? 


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