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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

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