Argument in a case involving the taxation of earnings de by americans from a foreign company. The ca focuses on an indiabased company with more than half of its ownership held by americans. It was brought forward by a plaintiff who objected to a clause in a 2017 change in tax law that would have required a onetime repatriation test. This is about two hours. The court squarely held us much just a few years following adoption of the amendment. The it is undpud that the petitioners realedothing froms are stock investment. They were taxed not because they have no income but because in 17hey happened to owe shares in a corporation carrying retained earnings on its bks this is a tax on the ownership of property and therefore must be apportioned. The government cannot identify a single thing congress could not tax income underts position that reazation is unnecessary. Thout realization there is no limiting principle. Excepting the governments position on income would make a hash of the curren
By americans. It w brought forward by a plaintiff who objected to a clause in a 2017 change in tax law that would have wired a repatriation tax. This is about two. The court squarely held us much just a few years foowg adoption of the amendment. The the presidt kes easy work of the case. It is undisputed the petiors realize nothing from their stock investment. They were taxed not because they had income but becse in 2017 they happened to own sharein corporation. This is a taxn e ownership of property. Dispensing with the need for realization, the framers regarded this as the essential chec on the power of congress to taxrorty. The government cannot identify a single thing congress could not tax its income under its position realization is unnecessary. Without realization there is no limiting principle. Accepting th government position on income would make a cap hash of the current law. Gateway defition of gross income asserts congresses taxing por der the 16th amendment roh reaching al
and author ernie suggs. ernie asked you all probably know covers race and culture for the atlanta journal-constitution . he s a graduate of north carolina central university and we thank the alumni association for their support. he was selected as a nieman fellow at harvard university nowserves on the fellowship board . don is a multi talented graphic artist and designer. he got his formal training at columbus college of art and design in columbus ohio and those of you who have already gotten a copy of the book the many lives of andrew young will see don s amazing work in the layouts there. i had the pleasure of working with don when he created an exhibit at the kings center. it was an exhibit about president carter and martin luther king, both atlanta nobel peace prize were winners. then most importantly, ambassador andrew young. there has been a lot said about ambassador young over the past week and you will hear a lot more tonight. i just want to relay one personal story
he was selected as a niemann fellow at harvard university and now serves on the fellowship board. don bermudas is a multi-talented graphic artist and designer. he got his formal training at columbus college of art and design in columbus, ohio, and those of you who are already gotten a copy of the book the many lives of andrew young. we ll see don s amazing work in the the pictures and layout in there. i had the pleasure of working with don when he created an exhibit at the king s king center. it was an exhibit about president carter and martin luther king both. of atlanta s nobel peace prize award winners and then most importantly ambassador, andrew young. there has been a lot said about ambassador young over the past week and you will hear a lot more tonight. i just want to relay one personal story that i think typifies andrew young to me. we hosted reporter catherine johnson a few years ago to talk about her relationship with coretta scott king, and she was in conversation
This is about two hours. The court squarely held us much just a few years following adoption of the amendment. The the president makes easy work of the case. It is undisputed the petitioners realize nothing from their stock investment. They were taxed not because they had income but because in 2017 they happened to own shares in a corporation. This is a tax on the ownership of property. Dispensing with the need for realization, the framers regarded this as the essential check on the power of congress to tax property. The government cannot identify a single thing congress could not tax its income under its position realization is unnecessary. Without realization there is no limiting principle. Accepting the government position on income would make a cap hash of the current law. Gateway definition of gross income asserts congresses taxing power under the 16th amendment through reaching all income from whatever source derived. If the government possession position in this case is right th