This educational guide is based on the linked primary sources. It is not a Court publication, is not affiliated with the Court, and is not legal advice.
In brief
Overview
The revenue rule is a longstanding principle that prevents U.S. courts from enforcing foreign laws that affect contracts.
Petitioners argue that the revenue rule bars both direct and indirect enforcement of foreign tax laws.
Background and question before the Court
According to Respondent, the prosecution alleges wire fraud that defrauded a foreign government of tax revenue.
What each side argues
Petitioner Position
Petitioners argue that the revenue rule bars both direct and indirect enforcement of foreign tax laws.
Respondent Position
The United States argues that restitution under the mandatory statute should be ordered and does not violate the revenue rule.
According to United States, absent clear congressional intent to override the revenue rule, statutes should not be interpreted to contravene it.
According to United States, there is no obligation for the United States to assist a foreign sovereign in enforcing its tax laws.
According to Respondent, prosecuting wire fraud serves United States interests independent of the foreign government's loss.
What happened at oral argument
Oral argument was held before the Supreme Court at 11:13 a.m.
What the Court decided
Why it matters
Terms to know
No glossary terms are available for this guide.
Primary sources
Read the source materials on the official site or open the immutable repository copy used for this guide.
- 83b90ef958dcab72e894-r1-1108b87382a89de1.pdforal argument transcript
Guide generated September 20, 2026. Automated validation accepted this version.