A Washington state couple is suing the government arguing a tax on repatriated assets violates the U.S. Constitution. https://t.co/uOKo7AWAO2
— Bloomberg Tax (@tax) September 30, 2019
A lawsuit alleging that the Section 965 transition tax is unconstitutional affords the opportunity to write Part 33 in my series of posts about the U.S. Transition Tax.
Part 22 of this series included a discussion of a paper by Sean P. McElroy which argued that the Section 965 repatriation tax was unconstitutional for the following reasons explained in the abstract: