December 12, 2023 | Moore v. United States: What’s at Stake
The tax community is closely watching Moore v. United States, the Supreme Court case that has drawn national attention because it could upend large parts of the tax code. Businesses, nonprofits, and tax experts have filed numerous amicus briefs. What could the case mean for the 16th Amendment and the government’s ability to collect taxes? How likely is the Court to rule for the Moores? And if it does, how large are the possible implications for current code provisions and future tax proposals?
Tax Analysts is offering this episode of Taxing Issues as a free service to the public, and all attendees can receive CPE credits. To do so, you must register for the webcast before it starts and log in no later than the scheduled start time. You also must request CPE credits before each webcast, and you must answer the polling questions that will be asked throughout the event.
ABOUT THE SPEAKERS
President and CEO, Tax Analysts
As the moderator for our Taxing Issues webinars, Cara objectively analyzes issues and asks probing questions that challenge panelists to explain and defend their positions.
When she’s not moderating Taxing Issues webinars, Cara provides strategic oversight for Tax Analysts. She has led efforts to improve the Tax Notes suite of products and to aggressively pursue transparency in the administration of tax systems. Previously, Cara managed the editorial department, including the flagship daily news publications and weekly magazines. She has written for a broad range of tax policy publications, including Tax Notes State, The Tax Adviser, The Hedge Fund Law Report, and The Hill. She regularly speaks at tax conferences and other events, discussing a variety of technical tax issues as well as the need for transparency in tax administration.
Cara has a BA in political science and a BA in international studies from the University of Evansville and a JD from the George Washington University Law School.
Irwin I. Cohn Professor of Law and director of the International Tax LLM Program at the University of Michigan
Reuven S. Avi-Yonah is the Irwin I. Cohn Professor of Law and director of the International Tax LLM Program at the University of Michigan. He specializes in corporate and international taxation and has served as a consultant to the US Department of the Treasury and the Organization for Economic Co-operation and Development (OECD) on tax competition. He also is a member of the steering group for OECD's International Network for Tax Research.
Avi-Yonah is a member of the American Law Institute, a fellow of the American Bar Foundation and the American College of Tax Counsel, and an international research fellow at Oxford University's Centre for Business Taxation. In addition to prior teaching appointments at Harvard University (law) and Boston College (history), he has practiced law with Milbank, Tweed, Hadley & McCloy in New York; with Wachtell, Lipton, Rosen & Katz in New York; and with Ropes & Gray in Boston.
He has published more than 250 books and articles, including Advanced Introduction to International Tax Law (Elgar, 2019), Global Perspectives on Income Taxation Law (Oxford University Press, 2011), and International Tax as International Law (Cambridge University Press, 2007).
Partner and chair of the tax practice group at Klehr Harrison Harvey Branzburg LLP
Mark, a partner at Klehr Harrison Harvey Branzburg LLP, is Chair of the firm’s Tax Practice Group. For more than 35 years, he has concentrated his practice on advising clients on the federal, New York State, New York City and international tax and business aspects of a variety of complex domestic and cross-border transactions as well as handling high-stakes federal, New York State and New York City tax controversies.
Mark has decades of experience applying his broad and deep knowledge of the tax law and his understanding of business transactions to come up with creative and effective approaches to achieving clients’ business objectives in a tax-efficient manner. He has guided business entities and high-net-worth individuals through the federal, New York and international tax rules applicable to their domestic and cross-border transactions involving, for example, corporations, partnerships, joint ventures, investment funds, limited liability companies, S corporations, real estate investment trusts and debt workouts. In tax controversy matters, Mark has extensive experience successfully representing individuals and entities at the audit stage, at the administrative appeals or conciliation level and where necessary at trial and on appeal. Mark’s experience in this connection includes federal tax controversy matters involving domestic tax issues such as assignments of income, reasonable compensation and the proper treatment of interest income and expense and international tax issues such as source and characterization of compensation and royalty income, transfer pricing adjustments and the application of tax treaties, as well as New York State and City tax controversy matters involving issues such as statutory residency, domicile, source and characterization of income and deductibility of interest.
Mark is also a frequent author and presenter. He has been a co-editor of the Business Entities Journal’s International Taxation Department, the pass-through entities columnist and a member of the Board of Advisors and Contributors of the Journal of S Corporation Taxation, and a member of the Board of Advisors of the Journal of Limited Liability Companies.
Senior legal reporter at Tax Notes
Andrew Velarde is a senior legal reporter for Tax Notes Today International. In addition to managing the TNTI legal reporter team, he has been writing for Tax Notes since 2013, and now focuses mainly on U.S. international tax and administrative law. He has been a Society of Professional Journalists DC Chapter Dateline Award Finalist. Before joining Tax Analysts, Andrew worked at Deloitte, in their international tax practice group. Andrew graduated from the University of Virginia with a degree in commerce, received a JD from George Washington University School of Law, as well as a Master of Accountancy from GW.