Jones Walker Logo
  • News & Insights
  • Professionals
  • Services
  • News & Insights
  • Professionals
  • Services

  • Firm
  • Offices
  • Careers
  • Events
  • Media Center
  • Blogs
  • Contact

  • text

News & Insights

"Moore Gives Taxpayers a 'Gotcha' Argument In Factor Representation Cases," SALTy Thoughts, Tax Notes State

By Alysse McLoughlin

Article

September 9, 2024

Alysse McLoughlin and Katie Quinn, partners on the state and local tax team in the New York office, authored the article "Moore Gives Taxpayers a ‘Gotcha’ Argument In Factor Representation Cases" published in the SALTy Thoughts section by Tax Notes State on September 9, 2024. In the article, Alysse and Katie discuss the Supreme Court's decision in Moore v. United States and its implications for taxpayers, highlighting that the case’s rationale lends support for the argument that the factors of the foreign companies generating 965 income or GILTI must be included in the US shareholder’s state apportionment factor.

Related Professionals
  • name
    Alysse McLoughlin
    title
    Partner
    phones
    D: 646.768.7228
    email
    Emailamcloughlin@joneswalker.com

Related Practices

  • State & Local Tax
Sign Up For Alerts
© 2025 Jones Walker LLP. All Rights Reserved.
PrivacyDisclaimerAvident Advisors
A LexMundi Member