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Articles by Ramon Camacho
Moore Petitioners Make Strongest Case to Toss Repatriation Tax Original
The latest filing in the closely watched tax case Moore v. United States has made a stronger case for the US Supreme Court to invalidate the mandatory repatriation tax, which observers say could lead to billions of tax refunds to US multinationals. Taxpayers Charles and Kathleen Moore’s Nov.
Moore Petitioners Make Strongest Case to Toss Repatriation Tax
The latest filing in the closely watched tax case Moore v. United States has made a stronger case for the US Supreme Court to invalidate the mandatory repatriation tax, which observers say could lead to billions of tax refunds to US multinationals. Taxpayers Charles and Kathleen Moore’s Nov.
US Wealth Tax Could Gain Footing With Supreme Court Moore Ruling Original
Most of us thought Moore v. United States was a dispute about income taxes. It now appears the case could decide whether Congress has the power to impose a federal wealth tax. The question before the justices is straightforward—can the IRS tax the shareholders of a foreign corporation on the company’s income without a cash dividend or other distribution? Partners are taxed even if no cash is distributed, so could the same rule apply to corporate shareholders?
Seven Tax Questions U.S. Companies Might Ask Before Expanding Overseas
Custom Content by the Los Angeles Business Journal By Ramon Camacho Monday, October 25, 2021 With global tax reform shifting toward greater tax transparency and governments in need of revenue, U.S. companies seeking to expand into new markets or establish new businesses internationally should carefully consider these international tax-related questions. 1. DO YOU HAVE A PERMANENT ESTABLISHMENT (PE)?
COD income and cross-border considerations
Editor: Lori Anne Johnston, CPA, J.D. During periods of economic uncertainty, U.S. multinationals may need to modify or restructure the terms of their existing debt. Debt modifications or restructurings can take many forms — such as exchanging existing debt for new debt or for stock or modifying key terms (like interest rates or payback period).
Immune Enhancing Effect of a Growth Hormone Secretagogue
Gloria C. Koo, Christopher Huang, Ramon Camacho, Charlotte Trainor, J. Tom Blake, Anna Sirotina-Meisher, Klaus D. Schleim, Tsuei-Ju Wu, Kang Cheng, Ravi Nargund and Gaylord McKissick J Immunol March 15, 2001, 166 (6) 4195-4201; DOI: https://doi.org/10.4049/jimmunol.166.6.4195 Abstract Growth hormone (GH) has been known to enhance immune responses, whether directly or through the insulin like growth factor-1, induced by GH.
Individual election to be taxed at corporate rates
Editor: Lori Anne Johnston, CPA, J.D. The law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97, brought new attention to a provision of the Internal Revenue Code that had long been forgotten: Sec. 962, Election by Individuals to Be Subject to Tax at Corporate Rates. This provision was enacted as part of the Revenue Act of 1962, P.L. 87-834, which introduced the Subpart F rules of the Code.
IRS Eliminates Current Tax on Certain Off-Shore Income
RSM US LLP is an IMA Member On Oct. 31, 2018, the Treasury Department (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations (REG-114540-18) (the Proposed Regulations) updating the application of section 956 of the Internal Revenue Code (the Code) to account for changes to the U.S. international tax system due to the Tax Cuts and Jobs Act (the TCJA).
Frequently Asked Questions on Country-by-Country Reporting
RSM US LLP is an IMA Member The IRS has issued final regulations requiring annual country-by-country reporting (CbCR) by some U.S. taxpayers that are the ultimate parents of a multinational enterprise (MNE) group.
IRS releases Canada-U.S. competent authority agreement
The IRS has recently released a competent authority agreement with Canada, (The Agreement), which allows for the exchange of country-by-country (CbC) reporting information between Canada and the U.S. The Agreement entered into force June 7, 2017 but was not released publicly until October 2017, and will facilitate the rapid exchange of information collected under each country’s CbC reporting rules.
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