When an Income Tax Isn’t an Income Tax: Unpacking the Moore Case

February 6, 2026 - Participants include:   Professor Hank Adler - Chapman University   John Richardson - Toronto, Canada - @ExpatriationLaw   On January 29, 2026 Tax Notes published the following article by Professor Adler:   "When An Income Tax Is Not A Tax On Income"   The following podcast discusses Professor Adler's article ...   AI generated description:   "John Richardson interviews Professor Hank Adler about the Moore case and a rarely discussed constitutional issue: taxing undistributed foreign earnings using rates tied to a taxpayer's liquidity rather than its income. Adler argues this departs from the 16th Amendment’s promise of an income tax. The conversation also covers retroactivity concerns, potential state-level experiments like California’s proposed wealth tax, and the broader implications for tax policy and constitutional limits."