share your opinion in one paragraph on the Moore v. United States case.

Moore v. United States: Tax Unrealized Income Case (taxfoundation.org)

If the Supreme Court strikes down the entirety of the deemed repatriation for corporate and noncorporate taxpayers, we estimate this would reduce revenue by about $346 billion over the next 10 years, including a refund of tax payments made from 2018 to 2023 (see Table 1). If deferral on profits domiciled abroad were reinstated, we anticipate firms would adjust their behavior. However, our estimate does not account for this effect, which could further amplify the projected revenue loss below. If the Supreme Court's decision more narrowly strikes down the deemed repatriation tax for passthrough firms and individuals only, we estimate that this would reduce overall revenue collections by about $3.5 billion over the next 10 years inclusive of payments made since 2018. Pass-through firms and individuals account for a very small portion of deemed repatriation tax revenue, constituting only about 1 percent of the total tax owed according to Internal Revenue Service (IRS) data. For certain pass-through firms and individuals, this scenario could result in higher taxes, since they do not get the dividends received deduction and therefore any foreign earnings actually brought back to the U.S. would be subject to tax in the absence of 965. This interaction is not included in our revenue estimates below but is worth noting as it may not be expected for the affected taxpayers