No. 22-800October Term 2023Decided Jun 20, 2024
Moore v. United States
This case challenged the constitutionality of the Mandatory Repatriation Tax, a one-time tax on the accumulated, undistributed earnings of foreign corporations controlled by American shareholders.
Case status
- Current stage
- Decided
- Latest event
- Decision released Jun 20, 2024
- What it's about
This case challenged the constitutionality of the Mandatory Repatriation Tax, a one-time tax on the accumulated, undistributed earnings of foreign corporations controlled by American shareholders. The Court upheld the tax, ruling that Congress has the constitutional authority to attribute an entity's realized and undistributed income to its shareholders and tax them on that income.
Question presented
Does the 16th Amendment authorize Congress to tax unrealized sums without apportionment among the states?
- Case path
United States Court of Appeals for the Ninth Circuit / Decision released Jun 20, 2024
- Area
Business and Regulation
Documents
Related cases




Grounding
- Grounding
- Primary-source trail available.
- Note
- Plain-English explainer. Official filings and opinions remain authoritative.
- Checked
- Mar 30, 2026
- Method
- Methodology
Primary materials8
Supreme Court docket 22-800
docket | Mar 30, 2026
Primary case document
Supreme Court document | Mar 30, 2026
CourtListener docket record
docket | Mar 30, 2026
Questions Presented
brief | Mar 8, 2026
opinion
opinion | Jun 20, 2024
Moore
opinion | Jun 20, 2024
Opinion
opinion | Sep 8, 2023
Petition
brief | Feb 21, 2023