The U.S. Supreme Court (“the Court”) has finally issued its decision in Moore v. U.S., No. 22-800 (“Moore”). The Moore case involved individual taxpayers who owned shares in a controlled foreign corporation (“CFC”) and were subject to the so-called “transition tax” of Internal Revenue Code Section (“IRC Sec.”) 965. In the end, the Court upheld the constitutionality of IRC Sec. 965, stating that “Congress has long taxed shareholders of an entity on the entity’s undistributed income, and it did the same with [IRC Sec. 965].