UHND.com - Notre Dame Football, Basketball, & Recruiting

...from the attached article...
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The 7-2 decision, issued June 20, was expected to have implications for the taxation of wealth in the U.S., not just for U.S. taxpayers with substantial ownership in certain foreign corporations. Justice Amy Coney Barrett wrote a concurring opinion, joined by Justice Samuel Alito. Justices Clarence Thomas and Neil Gorsuch dissented.

...further...

In finding for the government, the Court affirmed the 9th Circuit Court of Appeals. That court highlighted that the MRT was designed to close loopholes that allowed shareholders to evade taxes on offshore earnings. By upholding the tax, the Supreme Court essentially reinforced the government's ability to tax foreign-held profits — at least in the circumstances described in this case.

...and in closing...

Wealth tax: Bottom line

When the U.S. Supreme Court agreed to hear this case, some believed the legal battle over taxing what the petitioners have described as unrealized gains might significantly impact tax policies for the wealthy.

Examples include billionaire taxes proposed by President Biden, Sen. Elizabeth Warren (D-Ma.), and U.S. Senate Finance Committee Chairman Ron Wyden (D-Ore.). (Biden's FY25 budget proposal includes a billionaire tax that would apply to households with a net worth of over $100 million. Wyden’s Billionaires Income Tax Act proposes to end the “buy, borrow, die” tax strategy.)

Those, and other so-called "wealth tax" proposals in several states that can involve unrealized gains, are a reason why the Moore case was seen by some, as a strategic move in a broader tax policy debate.

In the majority opinion, Kavanaugh noted that the court was not attempting to resolve certain other thorny tax questions including those involving wealth or net worth, signaling, "Those are potential issues for another day.”
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Some feel that amassing capital and then passing it on to heirs - tax free - increases the already expansive 'Wealth Gap' in this country and unnecessarily increases the tax burden of others w/o such access to capital. As Justice Kavanaugh said..."Those are potential issues for another day."


Link: https://www.kiplinger.com/taxes/unrealized-gains-tax-upheld-by-supreme-court