URG
Ur-Energy Inc.
stock NYSEAMERICAN

Moore said that income earned by the corporation could be taxed even if it hadn't been distributed. This seems straightforward as we already tax S-corporations that way.
Moore said that Eisner was relevant. The court said it wasn't relevant to this case.
That's different from saying that they reviewed Moore and said it was a sound decision.
And, Eisner wasn't about taxing unrealized gains. The theory is that the same reasoning would prevent URG taxes, but that has not been explicitly tested.
That said, I'm pretty sure this court would rule against a tax on unrealized gains. And, this congress would not pass such a tax so this court won't get a chance to rule on the issue.
In the distant future, if we have a congress that would pass such a tax, we may also have a different court.

Moore said that income earned by the corporation could be taxed even if it hadn't been distributed. This seems straightforward as we already tax S-corporations that way.
Moore said that Eisner was relevant. The court said it wasn't relevant to this case.
That's different from saying that they reviewed Moore and said it was a sound decision.
And, Eisner wasn't about taxing unrealized gains. The theory is that the same reasoning would prevent URG taxes, but that has not been explicitly tested.
That said, I'm pretty sure this court would rule against a tax on unrealized gains. And, this congress would not pass such a tax so this court won't get a chance to rule on the issue.
In the distant future, if we have a congress that would pass such a tax, we may also have a different court.