Latest Posts
Search for:
Author

Joseph Judkins

Browsing
Joseph "Jud" Judkins is a partner in Baker McKenzie’s Tax Practice Group and serves on the group’s Tax Controversy Steering Committee. Jud focuses on federal tax controversy matters at every phase of a dispute, including audit, IRS Appeals, and litigation. The application of administrative law principles to Treasury regulations and IRS guidance is a core component of his practice. Jud advises clients on a broad spectrum of international and domestic tax matters, including challenges to the validity of regulations, participation in the agency rulemaking process through the submission of comments and testimony at public hearings, the scope and application of TCJA regulations, transfer pricing disputes, tax statutory and regulatory interpretation, and other domestic and international tax issues. Jud previously clerked at the U.S. Tax Court and served in the U.S. Navy JAG Corps. Jud concentrates on tax dispute resolution.
In Repatriation Tax

United States: Supreme Court upholds the constitutionality of the Section 965 Transition Tax

by and 6 Mins Read

In brief On 20 June 2024, the US Supreme Court ruled, in a 7-to-2 decision in favor of the government, to uphold the constitutionality of the section 965 transition tax in Moore v. United States. This case has been closely watched because it informs a potential future dispute concerning the legality of a wealth tax and significant longstanding portions of the US tax regime. The original question presented was whether, under the Sixteenth Amendment, income must…