Overview
On November 28, The Hill quoted Lawrence Hill in their piece titled, "Supreme Court to consider ‘quadrillion-dollar question’ in major tax case." The article discusses a US Supreme Court case, Moore v. United States, that has the potential to reshape the US tax code and cost the US government hundreds of billions of dollars in revenue. The issue is whether the federal government can tax certain types of "unrealized" gains related to property that people haven’t directly recouped the value, so they don’t have direct access to the money that the property is worth.
Regarding the potential effects of the decision, partner Lawrence Hill told The Hill: "If [the court makes] a specific realization requirement, then it could have an impact on many other provisions of the Internal Revenue Code, because there are provisions currently … that arguably diverge from the realization rule." He described these divergences as "very significant," saying the rules pertaining to taxation of partnerships, S corporations, grantor trusts, controlled foreign corporations and original issue discounts could be affected, in addition to entire accounting norms pertaining to tax accrual and adjusting valuations to a going market rate.
