Supreme Court Case Risks Massive Tax Hit, Joint Panel Warns (1)

Several provisions in the US tax code are at risk of constitutional challenges if the Supreme Court strikes down a levy on unrealized foreign earnings, according to a Joint Committee on Taxation memo.

Taxes on corporations’ foreign income such as Subpart F and the tax on global intangible low-taxed income, known as GILTI, would be vulnerable to legal challenge depending on how justices rule in Moore v. US, the nonpartisan tax scorekeeper wrote in a Tuesday memo to House Ways and Means Ranking Member Richard Neal (D-Mass.), obtained exclusively by Bloomberg Tax.

Justices will hear the case, brought by ...