Steve Rosenthal
@stevertax
Tax lawyer and policy analyst. Senior Fellow at the Tax Policy Center. I express my views only, no one else's.
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09-12-2017 13:26:24
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Hard to predict a ruling based on oral arguments, but U.S. Department of Justice was impressive today in Moore. Solicitor General Prelogar was nimble with her tax code citations. She had me at section 1248, gains from certain sales or exchanges of stock in foreign corporations.
As I explained, YA Global was a middleman that expected to profit on equity securities that it acquired from customers to resell. Just like private equity funds (corporate developers) are middlemen, with customers, in the purchase and resale of property. taxpolicycenter.org/sites/default/…
Great program on Dec. 6, I will join Robert Alt of the Buckeye Institute on a DC Bar panel session moderated by The Wall Street Journal’s Richard Rubin to discuss the prior day’s oral arguments in Moore v. U.S. Early bird registration ends tomorrow, rb.gy/wu7r7q
DOJ just filed a solid brief in Moore, supremecourt.gov/DocketPDF/22/2…… The question presented is whether the Court will accept Congress's wide latitude to lay and collect taxes, or revert a century to a contrived 'realization' rule, and blow up our tax code. taxnotes.com/featured-analy…